**The Manager's Tool Kit**

**for Environmental Compliance & Pollution Prevention**

**Module 5 of 6**

**A Telecast Originating from the BLM National Training Center in
Phoenix, Arizona**

**March 14, 2002**

This transcript is from the closed-captioning file produced during the
telecast.

It may contain errors and omissions in transcription.

Announcer: The Bureau of Land Management Satellite Network and the USDA
Forest Service present live from the BLM National Training Center in
Phoenix Arizona, the Manager\'s Tool Kit for Environmental Compliance
and Pollution Prevention. And now, the host of your program, Tony
Garrett.

T. Garrett: Hello and welcome to Module 5 of the Manager\'s Tool Kit for
Environmental Compliance and Pollution Prevention. In today\'s program
we\'ll focus on the Clean Air Act, the Clean Water Act, the Safe
Drinking Water Act, Spill Prevention Control and Countermeasure plans
and Environmental Justice. Once again we\'ve assembled a first‑rate team
of instructors, beginning with Martin Thrasher. An attorney in and one
of the leading authorities on hazardous materials issues. Welcome back.

M. Thrasher: Thanks for the warm‑up.

T. Garrett: All right. Also back with us is Frank Mills, the USDA Forest
Service national coordinator for environmental enforcement.

F. Mills: Good to be here.

T. Garrett: Completing our instructional team from BLM\'s Idaho state
office in Boise is

K. Gebhardt:. Hello, Karl. Karl Gebhardt thanks, Tony, I\'m happy to be
here and I\'m kind of excited about this segment because it involves the
Clean Water Act and Clean Air Act, which I think are the real bread and
butter of our environment compliance programs.

T. Garrett: We are very pleased you could be with us. Karl is Idaho\'s
hydrologist and environmental engineer. We are glad you were able to
come down from Boise. Here is our objective for today\'s broadcast. Upon
completion of this module, you\'ll be able to, one, identify and apply
correct management actions to comply with the Clean Air Act, the clean
water acted, the Safe Drinking Water Act and regulations governing the
spill prevention plans and two, you will an awareness how Environmental
Justice applies to resource management decisions. Here is our schedule
for today. And toward the end of today\'s broadcast, we\'ll present
another round of \"The HazMat Challenge.\" Once again, it\'s east meets
west as we test your knowledge about the material we\'ll be covering in
today\'s telecast. In today\'s game, every participant will be awarded
this very special prize. This is the official \"HazMat Challenge\"
T‑shirt. So stay tuned for \"The HazMat Challenge.\" We\'re very pleased
to welcome viewers from the Bureau of Land Management, the Forest
Service, U.S. Fish

&

Wildlife Service, the National Park Service, the Bureau of Reclamation
and anyone else who may be watching this morning. We want you to know
your participation is very important to the success of the satellite
training sessions and again to help you communicate in real time with
our instructors, we\'re going to use push‑to‑talk technology. We
encourage you to use those push‑to‑talk microphones when you have a
question or something to share with our instructors and other viewers.
Whenever you do push to talk, we ask you begin by stating your name,
your location. We will acknowledge your call and then you can proceed
with your question or comment. That helps us avoid confusion when more
than one person is calling in. And to help manage all this, we\'ll let
you know when it\'s ok to push to talk by putting a green light in the
upper right corner of your screen, like that one. And during periods
when we\'d prefer that you hold your questions for the moment, we\'ll
put a red light up in the corner like this. We\'ll keep the green light
on as much as possible because we do want to hear from you and make sure
that all your questions are answered. Now, if you did not get the phone
number and numeric pass code for the push‑to‑talk telephone bridge for
your agency, please call our operator at this number. If you don\'t have
a push‑to‑talk system at your viewing site, we still want to hear from
you. We encourage you to participate by telephone or by fax. You can
call us toll‑free at\.... Sites in the greater Phoenix area should
call\.... Send us a fax any time at\.... By now all of you should have
registered for the course and received the course training materials if
that you haven\'t done that, please see your agency\'s website to
download the tool kit. The websites contain a study guide and other
useful resources. Now to get Module 5 under way here Martin Thrasher.

M. Thrasher: I wanted to thank everyone for checking in this morning. It
makes us feel more comfortable here knowing there are folks out there
listening to the program. And also wanted to reiterate what Tony said.
Frank and Karl and I are all used to traditional stand‑up teaching in a
classroom setting and we\'re very used to interaction with the students,
so I really encourage you at any time to use your push‑to‑talk, get
ahold of us, don\'t worry about whether or not you\'re interrupting or
going back to a previous topic. We\'re glad to take your comments and
your questions. Now, during the first four modules we spent a lot of
time covering what we called hazardous materials, which is a rather
broad subject in itself. Now, in today\'s Module 5, we\'re going to be
turning to the Clean Air Act, Clean Water Act, Safe Drinking Water Act
and so on, and generally we talk in terms of pollutants. Again, these
are sets of very highly regulated materials and managers need to know
that there is a separate set of regulations and standards that apply to
all these different types of materials. Now, for study purposes, we tend
to take these components of hazardous materials and pollutants apart and
look at them individually, but we want to make sure that everyone
understands that they all have a relationship to each other. So even
though we talk about them in separate components, there are
interrelationships and we\'re going to be discussing some of that today
and particularly next week. Now, before we get started with the
substance of today\'s program, what I\'d like you to do is turn to the
knowledge assessment, which is in your downloaded material, dealing with
the Clean Air Act. If you don\'t have it downloaded, I\'m going to show
on it this camera over here and we\'re just going to go through these
questions quickly and kind of take a look at what you already know. So,
here\'s the first question in the knowledge assessment. And I\'ll show
these again for you so that you have time to answer them. True or false:
the Federal Clean Air Act only applies to Federal facilities in terms of
smoke management from fires. The second question is in two parts. The
National Ambient Air Quality Standards have been established for six
pollutants. They are: and we\'ve got an indication here on the side as
to their chemical names. The second part of this question is: an area
that meets the standard for any of these pollutants is said to be in
(what) for that pollutant whereas an area that does not meet the
standard for any of these pollutants is said to be in (blank) for that
pollutant. And finally, the last question: the Federal Clean Air Act
established a national goal to eliminate all man made (blank) impairment
in \"mandatory class 1 areas.\" So take a couple minutes here and I will
go through the questions that I\'ll show on the camera here and you\'ll
have a chance to answer them. all right. How did you do with that?
Let\'s go back through these questions and see how you did. The first
question was, true or false: the Federal Clean Air Act only applies to
Federal facilities in terms of smoke management from fires. Who got that
one?

Caller: Stephanie Nash from Arlington Square.

M. Thrasher: Yes, Stephanie. What\'s the answer?

Caller: False. And why is that false, Stephanie?

Caller: Well, first off, the key word \"only,\" and because it applies
to not just Federal facilities and not just from fires.

M. Thrasher: Absolutely correct. You got it all. It\'s not only, it\'s
not just Federal facilities and it encompass as lot more things than
just fires and we\'re going to be going over that. Let\'s look at number
2. Who had the answers to number 2, the National Ambient Air Quality
Standards have been established for six pollutants. Who had those?
Anyone? All right. Let me go ahead and go through these. The first one
is sulfur dioxide. Or SO2. The next one is nitrogen dioxide, or NO2. And
then we\'ve got Pb, which is led and then we\'ve got CO, which is carbon
monoxide. And then we\'ve got O3. That one is a little harder one. That
is ozone. And then finally, PM‑10. This isn\'t really a chemical
abbreviation, but it stands for particulate matter less than ‑‑ oops, I
got that turned Ron ‑‑ less than 10 microns in size. In other words,
those are the inhalable particulates that can get in the deeper reaches
of your respiratory system. We are going to be talking about National
Ambient Air Quality Standards in a moment. The next part of the question
was, an area that meets the standard for any of these pollutants is said
to be in, and who had that?

Caller: Stephanie Nash, Fish & Wildlife, warmington.

M. Thrasher: Yes, Stephanie?

Caller: Compliance.

M. Thrasher: All right, compliance.

Caller: And noncompliance.

M. Thrasher: And then noncompliance if they\'re not ‑‑ if they\'re not
meeting the standard and those are real good answers it shows real good
understand of what the program is about. There are actually two terms of
art that I want to introduce you to here that the terms of art are
called \"attainment\" and \"nonattainment.\" And when Stephanie uses the
term \"compliance\" and \"noncompliance\" it has the same meaning. We
are going to show some videos in a minute that talk about attainment and
nonattainment areas and that\'s what it\'s referring to. Ok. The last
question here, the Federal Clean Air Act established a national goal to
eliminate all man made (blank) impairment in \"mandatory class 1
areas.\"

Caller: This is Darrell Barnes in Worland. How about visual?

M. Thrasher: Visual. Good answer. Did anyone use another word there? Ok.
Well, Darrell is right on point. The term of art, and he\'s got the
right idea, the actual term of art is called visibility, but it\'s the
same idea. Good job. We\'re going to be covering all of these areas and
a few more as we go through the program on the Clean Air Act. That\'s
going to be the first major focus for this module today. Now, the Clean
Air Act is a Federal act, but for the most part you\'re going to find
that the states have accepted delegation of the program from the EPA.
It\'s also a permitting and enforcement statute. By that I mean that it
provides for a permit system so that air emission sources have to get a
permit in order to emit air pollutants. It\'s also an enforcement
statute, and that is that it provides for administrative sanctions,
civil remedies and criminal penalties for violations of the act. There
are actually two primary mechanisms under the Clean Air Act for
enforcing and reaching the goals under the act. The first mechanism is a
permit system for air pollutant sources, both new sources and
modification of existing sources of air pollutants. The second area is
the development of state implementation plans to control sources of
certain pollutants which are in nonattainment in certain areas. Now, the
centerpiece for the Clean Air Act are what are called the National
Ambient Air Quality Standards. National Ambient Air Quality Standards
have been developed for six pollutants designed to protect public health
and welfare. And you can see them there on the visual, the sulfur
dioxide, nitrogen dioxide, lead, carbon monoxide, ozone and particulate
matter less than 10 microns in size. Now, for each of these six
pollutants, the EPA has developed both primary and secondary standards.
The primary standards are designed to protect public health whereas the
secondary standards are designed to protect public welfare. Within each
state in the country we\'ve divided the states into air quality planning
areas, and each of these areas are either designated as attainment or
nonattainment areas for all of those six pollutants. An area that meets
or is in compliance with the national ambient air quality standard for a
pollutant is called in attainment for that pollutant. And conversely, if
an area does not meet the national ambient air quality standard, then it
is called in nonattainment for that pollutant. So when you hear the term
nonattainment and attainment, it\'s referring to the National Ambient
Air Quality Standards. You might note that an area can be in attainment
for certain pollutants and in nonattainment for other pollutants. I
think with that, if we don\'t have any questions at this point, what I
want to do is turn to a video that illustrates this concept of
attainment and nonattainment. This particular video is taken in an area
near Phoenix here. Now, notice that there are two different pollutants
for which this area is in nonattainment. One is the PM‑10 or the small
inhalable particulate matter and the other one is sulfur dioxide. There
are lots of other good issues in the video and we are going to talk
about those after we turn to the video, but let\'s go ahead and watch it
now.

We\'re located on the Tonto National Forest about six miles from Miami,
Arizona, on the proposed site of the Carlota Copper Mine. The Carlota
copper company proposed a surface copper mine and sulfuric acid
electrowinnowing facility on this location in 1999.

The Globe‑Miami mining industry contributed significantly to that copper
production. This is located to and within the Tucson know at that time
forest. In about 1995, a corporation proposed the Carlota copper
project. This was the first large open pit copper mine proposed in
Arizona in the last 15 years. As we learn more about the project,
several issues begin to emerge. One of those involved water resources.
There was a large concern that pumping to provide water to the mine
would dewater pinto creek, a perennial stream in the Sonoran desert,
something of value. Also there were numerous water quality issues
associated with the mine. There were also issues related to T & E
species, particularly the Arizona hedgehog cactus.

We would like to describe the location of the Carlota copper project.
Here is an air photo of the mining district in which Carlota is located.
Carlota copper project is located in this area here. As you can see
there are other mines in the district, there is a mine immediately
adjacent to Carlota and there is another series of mines approximately
six miles away. In in this particular case we found out that the Carlota
copper project was located within two nonattainment areas, that is,
historically both PM‑10 and sulfur dioxide had exceeded National Ambient
Air Quality Standards. This meant that we would have to address air
quality in more detail than we ever thought possible. Initially we
didn\'t recognize air quality as an issue in this ‑‑ in the NEPA process
and as a result, we weren\'t able to address conformity at the same time
as we addressed many of the other resource issues associated with the
mine. As a result, it resulted in slowing down the overall assessment of
the project. Snooty mission inventory that was created allowed us to
compare the total emissions of PM‑10 and the total emissions of sulfur
dioxide on the de minimis level of 100 tons per year for the two
pollutants. Unfortunately, both pollutants in our initial analysis
resulted in exceeding the deminute must level, so we had to further go
down the pathway of conformity determination. Our first step was to
determine the emissions inventory for PM‑10 on it and look at the major
sources of PM‑10, particulate production. This had to include both
primary and secondary sources, such as traffic to the mine, as well as
haul truck traffic, and production emissions. We also had to look at the
potential SO2 emissions would that come from emergency generators and
also the tailpipes of the trucks, the haul trucks. So we then continued
and created an emission inventory for the facility. We looked at both
PM‑10 sources and SO2 sources individually. We then compared these
emission inventories to the 100 ton per year de minimis level at which
below ‑‑ below which you do not have to conduct conformity determination
and above which you mug through conformity. At the time we did the
analysis, the totals of both pollutants were above the de minimis level.
As we looked at the emission inventory for sulfur dioxide sources, such
things as tail pipe emissions from haul trucks and emissions from
emergency generators, we looked at alternatives on how to reduce those
emissions. Carlota copper company was willing to take a condition within
the EIS of using low‑sulfur diesel fuel and this resulted in the
emissions for SO2 dropping below the de minimis level. This effectively
stopped us from having to go any further in the conformity demonstration
process. Unfortunately for PM‑10, once we had the full inventory, which
was above that de minimis level and we also applied rigorous controls on
haul road dust and production operations that generate PM‑10, we were
unable to get below that 100 ton per year level. This resulted in us
having to follow the conformity determination process further in proving
that we would not exceed or contribute to another nonattainment
violation, a violation of the national ambient air quality standard. So
what we did there was we used computer modeling in order to demonstrate
this, and we applied the rigorous controls that we could, but at that
point, we were able to demonstrate through the modeling that we were not
going to cause any further exceedances or slow the progress that was
necessary in getting the area into attainment. These were key steps in
the conformity determination process. We were not, unfortunately, done
at that point. As we did not feel that we had one of the key steps in
the conformity process, the Federal enforceability issue addressed
fully. In order to do that, we then went to the Arizona department of
environmental quality, who was issuing the air pollution permit for the
facility, and we cooperatively worked with them to get them to consider
including these conditions, such as the use of low sulfur fuel or the
watering schedule on roads, in order to maintain those levels and assure
in our public documents and the conformity determination that these
emissions would be at the level that they were stated at in the
analysis. These permit conditions were voluntarily added by Carlota
copper into the permit with the help of Arizona DEQ and we worked
together collect collectively to have a Federally enforceable permit
with the conditions that we found through the conformity determination
process, and we could issue a positive and affirmative conformity
determination that would allow the project to continue forward.

M. Thrasher: Ok. We\'re going to come back in a few minutes and talk
about some of the concepts that came out here in this Carlota tape, but
I wanted to introduce you to one other concept under the Clean Air Act
that\'s important to understand and then watch another video and then
we\'ll talk about both of them at the same time. This next concept was
introduced in this tape and it relates to state implementation plans or
SIPs. Now, any state that has an area that is in nonattainment for a
particular air pollutant must develop an enforceable plan that\'s called
a SIP in order to reach attainment, in other words, compliance with the
National Ambient Air Quality Standards. These SIPs have to contain
requirements for new or modified air emission permits that are granted
to certain facilities, and they also have to have mandatory measures
that communities are going to undertake such as reduced sanding of
roads, additional sweeping of roads, things like that, no drive days,
things like that, to reduce certain air pollutants. So that\'s what\'s
in a SIP. And as you got introduced to in the film and Frank is going to
talk about later, there\'s a Federal requirement for Federal agencies to
be in conformity with those state plans. What I\'d like to do now is to
turn to another video that illustrates some of these nonattainment
conformity issues. This particular one occurred in the Mojave Desert
area.

The dust that occasionally films the air in Southern California\'s
Mojave national preserve became a cause of concern for BLM land managers
and the State of California. A part of the preserve, located in the area
of Barstow and Victorville, serves as a prime example of that concern.
Because of the almost constant use of public land by the general public
and improvement industry. Gas and power lines built by heavy
construction equipment crisscrossed the landscape. Just like the offroad
vehicle trails found almost everywhere. El Mirage, an expansive dry lake
bed s a favorite spot for offroad motorsports and has even attracted
Hollywood film crews who use the lake bed as a backdrop for their next
production. Add to the mix several active mining companies using more
heavy construction equipment and the result was extremely high
concentrations of airborne dust. When the lack of air quality threatened
to endanger public health, roughly 20,000 acres of the Mojave owned by
BLM was designated nonattainment. Working in compliance with the Mojave
Desert air quality management district office, or AQMD, BLM helped to
develop a state implementation plan, or SIP, a plan designed to conform
to Federal environmental protection laws by reducing hazardous levels of
airborne pollutants such as PM‑10.

PM‑10 is one of a group of pollutants called criteria pollutants which
are directly regulated by the Federal Clean Air Act and the state Clean
Air Act but we\'re also concerned about hazardous air pollutants and to
a lesser extent odors and other things that cause a nuisance.

They can shut us down. It\'s no different than the Clean Water Act or
the endangered species act. So that possibility always exists. I mean,
you have to cross the Tsand dot the Is and basically do what we are
mandated to do, which is to perform Federal conformity, and that
conformity can be in several processes.

And we looked at a series of those that we probably were going to do
anyway and put those up front and say, ok, here\'s part of what our
plants are and these will reduce dust and that got us most of what we
needed to do.

One of the most critical concerns was how the public would react.
Designateing a large and popular area of public land as nonattainment
could present a problem.

Try to tell thousands of people coming from the L.A. basin or the
empire, no, you can\'t ride your motorcycle today because we might
produce too much dust and be in noncompliance with the Clean Air Act is
pretty hard to swallow or even comprehend. So we did what we thought we
needed to do, which was the right thing, proactive approach. .

Narrator: That proactive approach was to actively involve members of the
general public in writing the SIP, making them a part of the decision
making process.

The net effect was that they\'re onboard now and they understood and we
didn\'t have the kind of negative response or resistance to our plan
that we could have. In fact, they came to our adoption hearings in
support of the document.

Narrator: For BLM, taking care of their individual air quality
obligations making ‑‑ meant making sure their control measures would be
included in the SIP.

We incorporated those into the plan as control measures or commitments
by the Federal agency and also into the rule that was the implementation
instrument for the plan.

Narrator: The process of including BLM\'s Air Conformity control
measures was a simple yet crucial step to complying with AQMD and the
Clean Air Act.

So we were able to identify that those measures met the requirement that
that portion of the inventory and that land manager also was shouldering
their portion of the responsibility for control measures.

Narrator: When separate agencies come together to solve a problem,
communication between the two groups can mean the difference between
success and failure. The process of developing a working implementation
plan is no exception.

Communications is the biggest thing. You both learn from each other, and
for the air district, they wanted to know what our activities were and
being able to describe those activities on on our level and being able
to describe our activities and what we would like to do and what we have
proposed in terms of our planning that we thought would help the
situation.

Control measure could say one thing and the rule that implements that
control measure which is really what matters to a land manager could be
completely different. So if there is a disconnect between the land
manager, Glen, for example, the local Field Office and the group
developing the SIP, if there is a disconnect after the plan is
developed, then all that cooperative work is ‑‑ has been wasted.

Narrator: Air Conformity issues like the one that faced the Mojave
national preserve, and it is a success story and a reminder that BLM
land managers have a responsibility not only to the land itself, but
also to the air around it.

I think it was identified that almost a quarter of the dust produced
came off of BLM lands and that\'s a significant thing. We obviously are
indebted to the process to do something.

And it\'s really not that hard. I mean, it\'s something that, it takes a
lot of coordination, early ‑‑ up front early on, lot of coordination, a
lot of document writing, but it\'s achievable. We are proof that it\'s
achievable, and we will continue to do so. I\'m sure ‑‑ it\'s definitely
raised the comfort level of our Field Manager and our district manager,
that\'s for sure.

M. Thrasher: One of the things that I noticed in both these tapes when I
first started getting involved with the Federal land management
agencies, I heard a lot of discussion about smoke management, which is
obviously a very important part of your job, but it seemed like there
was a lot of focus on smoke management in terms of particulate control
and I think one of the things that this ‑‑ both these tapes illustrate
are that there are particulate matter issues raising from recreational
use and industrial use of Federal lands that are important as well. So I
wondered if, Frank, you or Karl had any comments about the films.

One thing, I think, Martin that is important for the managers to realize
is how far reaching these areas ‑‑ air issues go, from miles to
hundreds, if not thousands, of miles from their locations people are
interested in what the air quality is and you can affect a large area by
an operation or something that you\'re performing in a seemingly
harmless ‑‑ out in the hinterland kind of action. So it\'s really the
manager needs to start looking at interfacing with state and local
regulators who have the enforcement actions for this type of an event
and see where their event is going time pact the state further down the
air mass as it moves along. So that\'s a big important thing for our
managers to realize, is we need to really know where it\'s going to go
to and who it\'s going time pact outside the area that we\'re under our
control.

M. Thrasher: Right. I think particularly when you say the interface
between the urban areas and rural areas becoming closer and closer. So
it can be a lot of impact. Karl, did you have any observations about the
films? Karl Gebhardt I thought it was interesting, the Carlota case,
where they had gone through the de minimis process and found out that
under some of their actions that they were going to bust that level. So
that didn\'t end the process. They had to go through further analysis
and went into modeling and found out with certain kinds of practices
they could go ahead with the project.

M. Thrasher: Right. That\'s an interesting thing that comes out. A lot
of people think that we actually measure a lot of these air pollutants,
which they are mesh nerd some cases, but a lot of other cases they are
modeled to predict through computer prediction how much pollution is
going to come off.

F. Mills: And oftentime the manager needs to learn to step out of their
own professional training box. For instance, if the managers trained in
wildlife management or for tree and now they\'re ‑‑ forestry and now
they are faced with a technical, scientific issue, such as modeling of
an air quality, they need to make sure they get to an authoratative
person to give them advice as they are making decisions as to how to
implement the plans and things they are going to do, especially when
they are going to talk to the public. They need to be well informed
before they go to a meeting from a source that can give them some down
to earth issues to talk to the public about.

M. Thrasher: Great. Let\'s move on with that to another aspect that\'s
important to Federal land managers, and that deals with visibility
protection and air quality related values. When Congress passed the
Clean Air Act, it established a national goal to eliminate all man made
visibility impairment in class ‑‑ in mandatory class 1 areas. Now,
mandatory class 1 areas were defined by Congress to include
international parks, national wilderness areas, national memorial parks
exceeding 5,000 acres and national parks exceeding 6,000 acres that were
in existence in August of 1977. So how does this come into play with
regard to Federal land management agencies? Well, for any new or
modified air pollutant source, the air polluting ‑‑ the air permitting
agencies must consider whether emissions from those sources will have an
adverse effect on air quality‑related values, including visibility in
the mandatory class 1 areas and primarily we do this through conformity
reviews, and, Frank, could you go through that about conformity analysis
right now?

F. Mills: Sure. As a Federal land manager, you have heard us use this
term and in the films, conformity. Just exactly what does conformity
mean? It means that you as a manager have to look at every action that
you take, and these actions are really everything such as permitting,
who we\'re using as contractors, almost anything that you do as a
manager and affects the air quality you have to look at. You can see on
the screen the statement that\'s made by the statute. And this statement
is very specific about the things that we have to follow. But you have
to assure that your actions conform with all the implementation plans
and that means the plans that are put together by state agencies which
have the responsibility for enforcing these regulations. Now, it\'s
really important to know that the law gave the Federal agencies the
primary responsibility for conforming assurance. So we\'re the ones who
have to make sure. That we\'re conforming with those implementation
plans. , and specifically, a Federal action must not contribute to new
violations,. It should not change any ambient air standard qualities
that have been set by any state or Federal government and you can\'t
increase the frequency or severity of any existing violations. So it\'s
important, Martin, that as the managers are dealing with their
day‑to‑day activities they understand that conformity means they have to
look outside and see what the rules have been set by the state and the
things that we do have to conform with those rules and we\'re
responsible for enforcing that.

M. Thrasher: I think that\'s really an important point to conclude about
conformity. Sometimes I think the Federal agencies have gotten the idea
they don\'t have to comply with state rules. Here\'s a mandatory state
rule that they have to make sure they\'re in conformance with.

F. Mills: Right. We have a website that\'s available that you as a
manager, you can look on this website and get information on Air
Conformity issues, and this is one of those areas that you really need
to as a manager take the ‑‑ to take the time to go into these websites
and find out why and what EPA and the states are requiring us to do as a
Federal agency.

M. Thrasher: Thanks, Frank. Right now we have another video ‑‑

Caller: This is Stephanie in Arlington square. I have a question about
mandatory class 1 areas and in there it talks about national parks, and
it just seems like park service land. National wildlife refuges are not
included?

M. Thrasher: To my knowledge, national wildlife refuges are not
included. Do you know any different than that?

F. Mills: I don\'t have any information on that, but we can check and
find out.

M. Thrasher: Could you give us the specific refuge that you\'re talking
about?

Caller: Oh, I was just curious because it just mentions parks, and
that\'s National Park Service and I was just wondering, because you
talked about BLM lands, and maybe none of the BLM lands are mandatory
class 1 areas, but here in the handout it just talks about parks.

M. Thrasher: Right. The definition for the mandatory class 1 areas comes
straight out of the statute. So it\'s not a matter of interpretation,
and I don\'t know about any national refuge areas that are included, but
if we knew one specifically that you were thinking about, we could find
it for you.

Caller: Yeah, I was just talking generically. I don\'t have a refuge in
mind.

M. Thrasher: All right. All I can tell you is the definition for the
mandatory class 1s comes straight out of the statute and we have given
it to you just like that. It doesn\'t mention national refuge areas
specifically in the statute. I think with that ‑‑ thanks for the
question, by the way. I want to go to another video that illustrates the
conformity issue and also the visibility issues. This particular one
occurred in the Yosemite National Park.

Located on the western slopes of the Sierra Nevada mountains, Yosemite
National Park has long been one of the crown jewels of the nation\'s
national park system. But over the years, as populations have swelled
and visitor days increased, so, too, have the by products of this
growth. Traffic congestion and poor air quality.

Yosemite National Park like many of the areas of the Sierra Nevada
mountains are faced with challenging air quality issues, and being a
national park, of course, we are concerned about the health of the
natural and the cultural resources within the park.

We\'re a class 1 park, which means that we kind of have an obligation to
maintain the air in as pristine a quality as possible.

Narrator: Faced with these challenges, the park set outed to planning
that would improve both traffic and air quality. However, park officials
quickly realized two things. One, that they weren\'t alone opinion and,
two, that these issues went beyond the traditional boundaries of the
park.

Yosemite is what we would call a downwind area. They are downwind of all
the urbanized areas in the San Joaquin area, which is one giant
nonattainment area. The whole central Valley of California is
nonattainment area for PM‑10 and ozone. It covers not only Yosemite but
all the counties.

Narrator: Park employees saw that conformity issues were now part of the
mix when it came to transportation planning in the park\'s rural
setting.

We took great care in really understanding what our visitors were doing
in terms of movement throughout the park, and once we had a good
understanding of that, we did quite extensive analysis on what the
different traffic options would do to congestion and what the air
quality impacts would be.

When we started looking at the Yosemite plan, the Yosemite Valley plan,
we had people on staff who saw that it was in our best favor to start
working with the transportation agencies to start to lay out our vision
of where Yosemite National Park needed to be and how that tied with
transportation, what things would work, what things won\'t work, and
then when you start looking at transportation, you also get to address
air quality issues under transportation quality conformity.

Yosemite was the first land management agency at the Federal level we
have worked with in terms of air quality conformity issues. The
designation of the rural areas is such that they never had this
experience before, and the regulations that we have to go by were
intended to be dealt with in terms of an urban setting, and so it\'s
kind of a learning experience for awful us as we go forward.

Narrator: Receiving guidance and leadership from Caltrans and the EPA,
Yosemite proceeded with its air quality monitoring program knowing the
data collected would provide valuable information to those neighboring
agencies who would have to be part of the solution. But how exactly does
an Air Conformity plan work?

Basically you have transportation agency whose doing a long‑range
transportation plan, 20‑year plans. On the other hand you have air
quality agencies who are also doing more short‑range, 10 ‑‑ 5 to 10 year
air quality plans. What conformity does is it links the two together.
Through the air quality plan they are required to do what we call an he
missions budget, a mobile source emissions budget, which puts a cap on
how much motor vehicle emissions can be exist in the area and maintain
the air quality standards. Now, that cap, that motor vehicle emissions
cap is the link. When the transportation plan is updated on a periodic
basis, they have to stay within that cap. If they don\'t stay within
that cap, then there\'s a problem, and they need to either revise the
transportation plan or look for new control measures to keep the air
quality clean in the area.

Narrator: And what happens if agencies don\'t meet or maintain Air
Conformity within a region?

Some of the potential consequences, if an area isn\'t able to show that
they\'re in attainment for air quality, or the agencies aren\'t able to
work together to achieve that, which we all want to avoid, is that
Federal transportation dollars can be shut off for transportation
projects, at least on a temporary basis, and projects that we\'re
banning on having Federal transportation dollars or projects that are
designated to be regionally significant, no matter what their source of
funds, cannot proceed forward. In order to assure ‑‑ ensure that we
don\'t reach the point where sanctions are being imposed,ology of the
agencies involved in a nonattainment area need to work cooperatively. If
one of those agencies is not participating in providing the information
needed for the analysis and to demonstrate the conformity, it affects
all of the agencies in that jurisdiction. If sanctions are imposed, it
goes nonattainment areawide, even though only one agency may have been
the reason why the nonattainment area or the demonstration of attainment
wasn\'t able to be achieved.

I believe that if we would not have embarked on this planning process
today with the trends in California we would continue to say the use of
the individual automobile continuing to come to Yosemite National Park,
and I honestly believe that we would be forced into saying that we
can\'t handle the visitation any longer. By looking at transportation
planning as another way of getting people to the park, we don\'t have to
turn them away because their car can\'t fit or because their car is
contributing too much pollution. The greatest advice I could give
anybody who is working in the planning arena as a Federal land manager
or just in a protection arena of your resources, whether or not in a
force, service, park or BLM lands, is know your other agencies. Know who
they are. Know what they do. And see how you can work together. Because
we all want to work within a larger framework. And then the other thing
I would suggest is, try and break down your barriers. Try not to talk
about your differences. Talk about your common goals.

I would advise other Federal land managers to do two things. One, to not
be afraid to ask for help. What that\'s your state D.O.T. and EPA is
there to do. They\'re here to help you and they want to do that and they
can provide a lot of valuable resources. And the second thing I would
advise a Federal land manager is to don\'t get overwhelmed by the big
picture of conformity. It\'s very ‑‑ it\'s technical. It\'s complicated.
And it just seems like a big thing to tackle. But just tackle it one
problem at a time.

I think one of the most important things that needs to be considered as
agencies embark on this nonattainment and air quality conformity process
is the interagency consultation aspects. It\'s part of the guidelines,
but really it\'s the key to get things done. It\'s more than just
guidelines and procedures. The agencies need to come together. They need
to agree how they are going to proceed. They need to agree on what roles
and responsibilities they\'re going to take. They need to agree on how
they are going to reach consensus can and they need to make agreements
along the way. Cooperation is really the key.

M. Thrasher: As you can see, one of the recurring themes in all of these
short videos is the need for cooperation and interaction with a number
of different agencies. It simply isn\'t possible for Federal land
managers to operate in a vacuum on their own land. There\'s just too
much interaction with the other agencies that are state and Federal
agencies and local agencies that are important. What I would like to do
before we turn to the next video is just introduce you to one other
topic under the Clean Air Act, and that deals with what are called
operating permits. Many major air pollutant sources are required to
obtain what\'s called an \"operating Permit and that permit consolidates
all of the sources of air pollution from a single facility under one
permit. So if you\'ve got a powerplant or a smelter or a mine or any of
these major industrial sources, they\'re going to have an operating
permit that allows them to release certain air pollutants. It\'s also a
very good source of information on facilities that are using Federal
lands. You can obtain lots of information about their air pollution
emissions from those sources just by looking at the permits. I think
with that what I would like to do is turn to the next video, which is
the ‑‑ is out of Aspen, Colorado, and it actually talks about a
modification of a permit for a ski area there, as well as several of
these other topics that we\'ve covered. Let\'s watch the Aspen video now
and then we will talk about it a little bit.

Aspen is an internationally famous ski resort and we have high mountains
obviously right around town. Aspen itself is in the bottom of a Valley.
Pollution gets trapped by the mountains and high altitude and sometimes
it gets trapped right around town and then we have a lot of sources in a
small area because there\'s a lot of traffic and lot of wood‑burning
fireplaces and restaurant grills. 86% of our PM‑10 on a bad day comes
from cars driving on paved roads. The big issue was, how to get people
to drive less, and how to provide enough alternatives so there were
attractive alternatives and it wasn\'t just a matter of trying to get
people out of their cars but giving them attractive choices instead.

That\'s our biggest concern in an area like Aspen, is the road dust that
impacts air quality in the area. So it\'s important to have high‑quality
transportation information and then also when we\'re discussing
mitigation, that we have a good analysis of what the mitigation measures
would do to reduce traffic to acceptable levels.

And for a case like this, we did a very detailed analysis of what the
air quality impacts would be. We worked with the state and city and
county to make sure we took everything into account everything from
restaurant grills, vehicle traffic, fireplace emissions, any other
source and did disclose that to the public.

Recent studies have shown that PM‑10 is more harmful to people\'s health
than we used to realize, even at levels we experience several times a
year. There is an increase in hospital admission rates and death rates.
It really is a public health concern. It\'s also why a lot of people
came to Aspen.

So when you can take cars off the road, put those folks on buses, on
other forms of transit, we see an elimination of the exhaust emissions
and of the road dust emissions that all those individual cars would
produce.

About a year after we had adopted our SIP, the snowmass ski area came in
with a proposal to expand and add new ski lifts. Since that would have
added more traffice with more skiers and employees and rooming and all
the activities, had that the potential to negate our efforts to clean up
our air. So then the ski areas was on Forest Service land and the Forest
Service wanted also to make sure that they didn\'t make a decision would
that interfere with our ability to keep our air clean.

In fact, the conformity regulations give us an affirmative
responsibility to comply with this section of the act. We have an
affirmative responsibility to make sure that our actions don\'t cause a
violation of a state implementation plan. That\'s the strongest language
Congress ever uses to tell an agency that they darn well better do
something.

Since we are at that time working the town of snowmass, the City of
Aspen, the county, all trying to come one a comprehensive transportation
plan, the Forest Service allowed us additional time to see if we could
come up with a comprehensive solution and if we didn\'t, they required
the ski company to purchase buses and operate the buses as a way to
inoffset the increases in traffic they would otherwise cause.

We in our record of decision, in our permit to the ski corporation,
required they do something to make sure there was no net increase. This
made the state happy this, made the local, the county happy, the city
happy. This made EPA happy and it made us happy, too, because not only
is this the legal thing to do, but it\'s the right thing to do. They
required a number of things, street sweeping, paved parking, remote
parking, things like that, so that they could bring the air quality
levels under the health standards and protect the health of the public.

So with a requirement that the developer add to the Aspen transportation
network of about 1 million of additional bus service, that was a very
good, innovative approach to mitigating the impacts of the expansion\'s
impact on air quality.

We did not do this analysis in a vacuum. As far as our conformed and
NEPA analysis looking at air quality issue. We made sure we worked
directly with the city, county, state and EPA to make sure we were all
using the exact same numbers in the analysis, that there would be no
bickering later on about, well, the analysis wasn\'t good because you
didn\'t include X, Y or Z. It was important to work with the air
regulatory community and the public affected to make sure the analysis
was good. Then after you do a good analysis, it\'s still incumbent on
the agency to make a good decision and in this case we did. .

For us it was essential to coordinate with all the agencies because our
nonattainment area includes different political jurisdictions and then
the state has to approve the SIP as well. There would be no point in
going forward if everyone didn\'t agree on what to do.

The final decision has to be made to ‑‑ by the land management agency.
The key is to make that decision based on good information that
everybody is aware of and then go ahead.

M. Thrasher: Ok. I think there are three major things that I wanted to
highlight out of these films. One is that the Federal agencies have to
conform to the state implementation plan designed to control air
quality. Second is the absolute need for cooperation and interaction
with several other agencies. It\'s absolutely critical. Then the third
thing is to have an illustration when that we talk about air quality
with regard to Federal land management, we\'re not just talking about
control of smoke. We\'re talking about other air quality issues and
other air quality sources. Now, with that, I certainly don\'t want to
diminish the importance of smoke management, because that is a very
important aspect of Federal land management and I\'d like to ask Karl to
discuss smoke management a little bit here at this point in the program.

Ok. Thanks, Martin. Karl Gebhardt we\'re going to turn now to another
video, but before we do that, we are ‑‑ the last video kind of got my
juices going with the skiing and it\'s been at least a day since I have
been on the slopes. So I want to get back going. But one of the things
that\'s different about the video you\'ll see next is that it\'s
actually the Federal agencies dealing directly with the permit issue.
It\'s something that we have to deal with with smoke management. When we
have to go in and maybe do some changes in our prescribed burning,
prescribed fire programs and have to go out and get these permits. I
think one interesting comment that was made in the last video was,
don\'t get overwhelmed by the conformity issue. You know, take one
problem at a time. I think that\'s really important. You\'re going to be
faced with a number of issues regarding smoke management, not just the
fire control aspects. So when you look at this next video, start
thinking about perhaps not only the smoke management sources but maybe
other sources that might be contributing to the entire PM‑10 problem,
and as you view this, keep notes and see if they think about the other
issues involved. Let\'s move to that video and this is the Globe ranger
district from the Tonto National Forest.

we\'re out on the Globe ranger district in the Tonto national forest and
the area near the Pinal Mountains. The Pinal Mountains are located
within the Hayden‑Miami PM‑10 nonattainment area. When the forest I.D.
team looked at the land management plan amendment for fire that\'s being
proposed, they analyzed across the landscape where the emissions would
change from the previous land management plan. One of the key reasons
for incorporating and addressing the conformity determination within the
land management planning process is that individual projects that are
subsequently done under the conformity determination that is done with
an LMP are assumed to be in conformity. This allow as reduction of time
and effort and dollars and also the ability to turn projects around much
more quickly.

Air quality is an issue in this area basically because of the
designation as a nonattainment area for the Hayden‑Miami nonattainment
PM‑10 area and this is one of the areas that will be covered by the plan
amendment for the Tonto National Forest. In the past history on the
district, there wasn\'t as much prescribed burn as we\'re being proposed
right now. Due to the proposal of possibly increasing those emissions,
we\'re going to need a conformity determination.

When the Tonto National Forest ID. team looked at the variety of
nonattainment areas, we have three that are significant, the Phoenix
nonattainment area for PM‑10, the Payson area and also the Globe‑Miami
nonattainment area for PM‑10. We looked at where we would be increasing
the burning and subsequent emissions from the previous LMP. Under the
conformity rule that\'s in place, land management plans that have been
in operation and in place on the ground prior to the conformity rule
being established were grandfathered in and they were assumed to
conform. So the ‑‑ a land management plan amendment would that result in
changes of emissions or specifically increases of emissions in
nonattainment areas would have to look at the conformity issue and
address conformity and in the PM‑10 nonattainment area for Phoenix, we
found that the management strategy that would be applied would be even
more aggressive management of fire and less ‑‑ or virtually no
prescribed natural fire or fire to be applied in the Sonoran desert
country, and with that, again, no increase in emissions resulting in no
necessity to address conformity. In the other two nonattainment areas,
in Payson, the emissions were calculated to be roughly the same as they
had been under the previous land management plan. So there was no change
and that no need to address conformity there. As a result, the only one
of those two ‑‑ of the three, rather, that would increase was this area,
in the Pinal mountains and the Hayden‑Miami nonattainment area.

Due to a number of reasons the area has an influx of residential houses,
lack of fire for quite a number of years, and that\'s led to kind of a
buildup of fuels in the area. Last summer, end of July, first of August,
we had the peak fire. That fire was about 2300 acres, and that, again,
was a type conversion. It took out an extremely large amount of
Ponderosa pine. It got into an area of the TUSEK moth bug kill we\'ve
had in that area, and was pretty devastating. We were fortunate we
didn\'t lose any summer homes or electronics site. Right now to me the
NEPA decision is right, the people that live up here definitely see the
problem that\'s happened with the peak fire, saw how close those summer
homes and integral electronic sites to Sky Harbor ‑‑ what I saw last
summer from the people that use the electronic sites to the people that
live in town is they\'re ready. This project needs to go and I think we
got some real good public support for it now.

We looked historically what kind of burning was done in the local area
and we calculated emissions from the previous plan. We then figured out
what needed to be done under the future plans that Anthony spoke about,
and we figured out how many days per year would be burned and the
emissions that would result. We used some computer modeling to analyze
what those air quality impacts might be, and we then verified through
the modeling that we would not exceed or contribute to a further
violation of the PM‑10 National Ambient Air Quality Standards. After we
an liced the results from the modeling and determined the number of
acres per day and the potential emissions, the modeling did prove
effectively that we would be not exceeding the National Ambient Air
Quality Standards. This strategy of modeling the impacts is one of the
accepted methods for doing a conformity determination and having an
affirmative conformity determination. We chose in this one to include
the conformity determination step in the NEPA process in order to
streamline the process and not lead to any delays caused by this air
quality issue. So we will follow that procedure, which is outlined in
the rules, and was intend to do allow this ‑‑ the ease and simplicity of
linking the two operations together.

K. Gebhardt: That was an excellent example of conformity analysis and
where you may be going as a Federal land manager. One of the things that
I think they brought out in the video real well was the idea of getting
public support for what you\'re trying to do, since it is ‑‑ it\'s kind
avenue thing. A couple of comments when you do go into a modeling
situation is that you may want to look the other sources than just your
prescription burning, such as construction and so forth, that may have
other sources of PM‑10, because they can affect your overall modeling
output. With that, I\'d like to turn it back to Martin and have him
continue.

M. Thrasher: Ok, thanks, Karl. That pretty well concludes our discussion
of the Clean Air Act. I did want to leave you with the thought that we
wanted to bring forward that particulate management, air quality
management means a lot more than just smoke management to the Federal
land management agencies. We\'ve got lots and lots of different sources
of particulate matter emissions. Here is one here that you might not
even think about, a parts washer has particulate emissions from it, and
as Karl mentioned, there are lots of other sources. Vehicles,
construction equipment and roads, that are very important in terms of
particulate management. Tony, I think with that, I think that completes
our discussion of the Clean Air Act. I would like hopefully to have some
questions or comments from the folks about the videos or anything else
that we presented.

T. Garrett: All right, thank you, Martin, thanks Karl, thanks, Frank,
and the green light is on. Sole we\' invite your questions or comments.
Just use that push‑to‑talk microphone and get in touch with us now.
We\'ll pause and wait to hear from you.

Caller: Tony, this is pat, South Carolina. Can you tell us how to get a
copy of the smoke management video? It is pat, if you will send us an
e‑mail, you can address that e‑mail to me, if you would like, and
that\'s\... send me an e‑mail and we\'ll arrange to get a copy of that
video to you. Pat ‑‑

Caller: Thank you.

T. Garrett: Tell me about your particular interest in that video.

Caller: We\'re in the process of doing mechanical fuel reduction, and we
feel the contractor is leaving too much debris on the ground, so we\'re
dealing with an FMP in progress, so I think this video would be a very
good one for us.

T. Garrett: We\'ll send one out to you. Any thoughts from our
instructors on that?

F. Mills: You know, Tony, we\'re really starting into a more aggressive
fuels management program and a lot more of our managers are going to
start needing to be involved in this type of a modeling effort.
Especially in areas that traditionally haven\'t had an aggressive fuels
management program.

K. Gebhardt: One of the things pat brought up was the contractors and
certainly when you\'re dealing with contractors, they have to kind of
understand your problem. So I think maybe showing them parts of that
video would be a good start and getting them to use the right practices
to kind of minimize your smoke management problem, but contractors
definitely can be a problem if it\'s not taken care of early on.

T. Garrett: All right. Thank you, Pat, for contacting us. We\'ll pause
for any additional comments or questions from our viewing audience.

Caller: This is Paul and I was curious about the copper mine situation
in Arizona. How much of that cost for the study am I paying for with my
taxes and how much is the actual copper company paying?

T. Garrett: Paul, thanks for that question. Let me make a technical
note, in your use of the microphone there, we need you to back away a
little bit so we can get a little bit better sound quality. Karl, some
thoughts on Paul\'s question?

K. Gebhardt: Yeah, in experiences with other situations, I know with the
cop ‑‑ not with the carp mine itself, because I\'m not familiar with
that, but with other situations where there is a company coming into
Federally managed land, they are oftentimes responsible for fronting the
costs for doing the environmental analyses and I would assume in this
case that probably happened. That\'s one of the things we have changed
over the last 15 years or so, to try to make the developers and mining
companies responsible for providing that kind of a document.

M. Thrasher: The same is true for the state agencies who are involved
with the permitting. They generally have permit fees. A lot of times
they charge on an hourly basis. So it depends on the complexity of it,
how much time it takes and how much they\'re going to charge. I\'m not
going to try to convince you that all of the government costs are
reimbursed by the regulated entities, but there certainly is a movement
in that direction.

F. Mills: I\'d like to also bring other another point, too. It\'s
important that you as a manager involve your other staff members in
these decision‑making processes, and especially bring them up to speed
on the reasons you\'re doing certain things. I\'ll use a specific
example. Our law enforcement staffs are often tasked with heavy
management burden of traffic management, and they\'re the ones standing
out there on these barriers and things and telling people, \"you can
only have so many cars per minute,\" and things like that through an
area. And oftentimes the law enforcement officer doesn\'t understand why
he\'s having to restrict traffic. So his answer to the public is really
an uninformed answer, where if you were to bring that staff member in
and set them down during the discussion of a conformity issue, they
would understand the overall environmental management and land
management issue that they\'re trying to enforce out there on the
highway, and that can lead to more informed answer to the public as to
why they\'re having to wait in longer lines and things to get into our
resources and that\'s so important that these other staff members who
are ancillary to helping us prevent the problem are given the chance to
be briefed on exactly what conformity means to the overall mission of
the land unit itself. So bring those other staff members in and tell
them what\'s happening and why we\'re doing a certain thing, or why
we\'re taking a certain action and that will help them do their jobs in
a better way.

T. Garrett: Thank you, Frank. We\'ve heard from some of the staff
involved directly in that Carlota copper mine issue, and they tell us
Carlota did pay not all, but almost all of the costs of that. So, Paul,
calling from one of the park service sites, we hope that information
helps address the question that you raised. Any other questions or
comments from our viewing sites around the country? Go ahead and get in
touch with us on the push‑to‑talk system. If your downlink site is not
equipped a push‑to‑talk system, we do have that toll‑free telephone
number. 1‑877‑709‑5346. Any other questions or comments from our viewing
audience?

Caller: This is Lamar in ‑‑ and ray from big thicket national preserve
just checking in.

T. Garrett: Good to hear from you, Lamar and thanks for checking in with
us. We hope you\'re getting something out of today\'s broadcast, Module
5 of the Manager\'s Tool Kit. Any other sites wish to check in, raise
questions or comments about the issues that we\'ve covered so far in the
first half of our program? Ok. Again, the fax number for any questions
or comments that you want to make any time during the program. Is
602‑906‑5713. Send us a fax any time and we\'ll get to your question.
One last time we\'ll invite our downlink sites to go ahead and push to
talk, get in touch with us now before we go to break and we\'ll address
any questions that you have. Frank, Karl, Martin, anything from you
before we go to break?

M. Thrasher: No.

F. Mills: No.

M. Thrasher: Think we\'re ready to go. All right, at this point we\'re
going to take a 15‑minute break. When we come back we\'ll take a look at
the Clean Water Act, the Safe Drinking Water Act and spill prevention
control and countermeasures plans. We\'ll discuss Environmental Justice,
and we\'ll have this week\'s round of \"The HazMat Challenge.\" Lots
more to come after this halftime break. We\'ll see you 15 minutes from
now.

T. Garrett: Welcome back to Module 5 in our Manager\'s Tool Kit series.
With us again for part of the 2 telecast, our lead instructor, Martin
Thrasher, Karl Gebhardt of the BLM and Frank Mills of the USDA Forest
Service. We would like to mention some upcoming telecasts\.... So please
mark your calendars for these important training events. And we hope
you\'ll plan to participate. Now let\'s get back to the Manager\'s Tool
Kit and turn to Martin Thrasher and a discussion of the Clean Water Act.
Martin?

M. Thrasher: Thanks, Tony. And we really appreciate all your questions
and comments during the first half of this module. So make to keep them
coming in. I was told during the break that when I was discussing the
mandatory class 1 areas relating to national parks that I used the
figure of 7,000 acres. The actual figure is national parks 6,000 acres
and above for that. Now what we would like to do is turn our attention
to the Clean Water Act, Safe Drinking Water Act and Environmental
Justice for the second part of this program. Again, what I would like to
do is challenge you with a knowledge assessment that you may have
downloaded with your material, and if not, then we\'ve got it on the
camera here to my right, and I\'m going to go through the questions
again real briefly, and then we\'re going to give you a few minutes to
answer them, and then we\'ll come back and go through the answers. So
the first question here is: mark all that are true: dumping snow in a
stream from a front end loader does not constitute a point source water
discharge because the snow is natural. a Federal agency must obtain a
storm water permit if it is going to clear more than 1 acre of ground.
thirdly, normally federal dredge and fill activities fall under a
nationwide permit so that no permit conditions will apply.

\> The second question: under the Safe Drinking Water Act, (blank)
drinking water standards are established to protect public health and
(blank) drinking water standards are established to protect public
welfare. And here\'s the third question. Again, we\'ll come back to
these in a minute so you can have a chance to answer them. SPCC plans
are required of all facilities, including Federal facilities, which have
underground oil storage capacity of more than (blank) gallons, or above
ground oil storage capacity of more than (blank) gallons or any above
ground container for oil storage neck zest of (blank) gallons. In
calculating the above ground oil storage capacity, the volume of what
size containers is included? All containers? Just containers a gallon
and above? Containers 5 gallons and largers? Or containers 55 gallons
and larger? The fourth question: the purpose of the president\'s
Executive Order relating to Environmental Justice is ‑‑ and we would
like you to mark all that are true. Focus Federal agency attention on
human health and environmental conditions in minority and low income
communities. Foster nondiscrimination in Federal programs. Or give
minority and low income communities greater opportunities for public
participation. So why don\'t you take a few minutes and I\'ll go back
through these cards showing them on the camera here, and you\'ll have a
chance to answer them.

M. Thrasher: All right. Let\'s see how you did with this knowledge
assessment. First one is a Clean Water Act question. Mark all that are
true. Who had those? Somebody come on and tell me the answers to these.
What about the dumping of snow into a stream from a front‑end loader,
does that require a permit, or is that ‑‑ because it\'s natural snow, it
doesn\'t need a permit? All right. The dumping of snow into a stream
from a front‑end loader does constitute a point source discharge under
the Clean Water Act, even though the snow may be natural as it falls, it
still contains pollutants such as salt and dirt and so on. So that one
is not true. How about the second one here, a Federal agency must obtain
a storm water permit if it is going to clear more than one acre of
ground? Who knows the answer to that one?

Caller: This is Coos Bay, Paul, in Oregon. I put true.

M. Thrasher: Absolutely. It used to be just several months ago that the
trigger acreage was 5 acres, but it\'s been reduced to one. So good
answer. How about the third one here about dredge and fill permits? Is
that true or false?

Caller: This is Paul again in Coos Bay, and we put down a true on that.

M. Thrasher: A true. Now, why do you think it\'s true, Paul? Paul, why
do you think that\'s true? Well, that\'s a very common answer to this
sort of thing and let me just cover it for you. Whenever you have a
permit, no matter where it comes from, there are always conditions
attached to that permit. So even nationwide permits have conditions
attached to them that you have to meet. Let\'s go to the second question
here relating to the Safe Drinking Water Act. Under the Safe Drinking
Water Act, what types of standards need to be developed to protect
public health? Well, those are primary standards. They\'re designed to
protect public health. And then the secondary standards are designed to
protect public welfare. Let\'s go to number 3 here. Who had this one?
What do the letters SPCC stand for? Who had that one?

Caller: This is Peter at Albright. Spill Prevention Control and
Countermeasure plans, and it\'s all containers.

M. Thrasher: spill prevention control and countermeasures. Absolutely
right. And they\'re required of all facilities which have a capacity ‑‑
I guess that was Paul, right? Paul, did you have an answer for this one
here? Oh, Peter. Which have an underground oil storage capacity of more
than ‑‑ how many gallons is this?

Caller: 42,000 gallons.

M. Thrasher: Absolutely correct. Now, what about the above ground
capacity? What did you have for that?

Caller: 1320 as long as none ‑‑ no single container has capacity in
excess of 660 and then down at the bottom it\'s all containers.

M. Thrasher: Absolutely. You got that right. The above ground is 1320 is
the trigger, and no larger container than a 660, and you include the
volume of all of the containers. The last question here related to
Environmental Justice. The president\'s Executive Order relating to
Environmental Justice and we\'re looking for all the true statements.
Who had that one?

Kim, Fish & Wildlife. They\'re all true.

M. Thrasher: Absolutely correct. They\'re all true. We\'re going to be
going through all of these again, so I\'m not going to read them for you
again. We\'re going to be going through them and having a video about
them. Good job on the knowledge assessment. Let\'s go ahead and get
started on our discussion of the Clean Water Act. The Clean Water Act is
designed in a similar fashion to the Clean Air Act in that it\'s
delegable to the states and so you\'re going to see most of the states
running the water act programs rather than the Federal government. And
it\'s also a permitting and enforcement statute. Its goals were to
eliminate the discharge of pollutants into surface waters in the United
States. Now, notice that the focus is on surface waters and not
groundwater. Whereas in most of the states, the state equivalents to the
clean water acts have included groundwater in their programs. A second
major goal of the Clean Water Act was to achieve a level of water
quality that provides for the reproduction, propagation, protection of
fish, shellfish, wildlife and to promote recreation in and on water, and
that\'s the so‑called fishable, swimable standard. The primary mechanism
for achieving these goals is through a permit system, and this permit
system is called national pollutant discharge elimination system, or
NPDS. A lot of people call it a NPDS. The idea under the permit program
is to to have a permit that is required for the discharge of any
pollutant to navigable waters from a point source, and you can see
we\'ve highlighted each of these very important terms, because as
managers, you need to have a basic understanding of what these terms
mean. Let\'s take a look at each one of them in turn. First of all, the
term discharge. That includes the addition of any amount or any type of
pollutant into a water, and there are a couple of minor exceptions to
that that we\'re going to cover a little later. But basically any amount
of pollutant of any type in the water constitutes a discharge. The next
concept that you need to be familiar with is the concept of what is a
pollutant, and basically under the Clean Water Act, a pollutant is
virtually anything that can be added to water. That can include
chemicals, sludges, sewage, garbage. It could include shotgun pellets,
dirt and it can also include such things as heat. So a change in
temperature constitutes a pollutant. A lot of times when people think
about pollutants they think about very dramatic things. I want to show
you a couple of illustrations of kind of some nondramatic pollutants
here. This particular photo is of a man made lake in Colorado Springs,
and right here in the foreground is a ‑‑ right here in this area is a
public swimming area. Well, in order to meet the swimming water
standards for the state, this ‑‑ the owner of this property has to put
chlorine directly into the water to make sure that the water is pure
enough to swim in, and here is a chlorine holding facility. They
actually have to have a permit to discharge that chlorine into that
water. So that\'s a pollutant even though it\'s there to protect the
public. This next image is of a bridge building ‑‑ bridge construction
operation, and you can see here in the background they\'ve constructed a
passageway for heavy equipment, and then there are pipes that actually
go underneath this little temporary roadway. Well, their concern here is
about pollutants from the trucks, including petroleum and including dirt
and mud and so on going into that water. So when you think about the
term pollutant, you want to think about it in a very broad sense. Now,
the next concept with regard to getting a permit has to do with
navigable waters. Because the discharge is prohibited without a permit
into what are called navigable waters, which includes all of the waters
of the United States, and this includes interstate waters, those that
transfer one state to another, they include intrastate waters and
impoundments and other forms of water in many different forms. Now, it
does not include groundwater, but as I mentioned earlier, a lot of the
states include groundwater in their programs. Now, a lot of us have an
image of navigable waters being a rather large body of water like this
one you see here, which is a large river, obviously you can float
commercial vehicles on it to transport goods in commerce, and so that is
a navigable water. So the concept of navigable waters is much broader
than that. Here\'s a small frozen pond area that\'s actually part of a
drainage from a hillside area, and that also would be a navigable water
or waters of the U.S. under the Clean Water Act system. This next image
is rather an odd inclusion in the term of navigable waters ‑‑ navigable
waters. This is the same man made lake I described to you earlier. You
can its normal water mark is clear up here around the edges. You can see
the geese that use the water. It\'s almost dried up during this winter.
So there\'s hardly any water. This is a man made lake. It has virtually
no outfall to it. And the makeup water for it comes from the potable
water supply, but again that\'s a navigable U.S. Walter ‑‑ water under
the definition of the Clean Water Act. The next important point with
regard to water discharge permits has to do with a point source, because
a permit is required for any discharge from a point source. A point
source is defined as any discernible, confined and discreet conveyance
from which pollutants are maybe discharged into waters of the U.S. A lot
of times we think of rather large pipes or traditional discharges as
being point sources and here you see ‑‑ I don\'t know if you can tell in
the background, but this real large plant facility is a large municipal
wastewater treatment plant. The discharge from that plant comes through
this channel right here, a concrete structure and then a channel where
they discharge the pollutants into the receiving water, which is this
creek right here. Well, that\'s kind of our traditional view of a point
source but we need to expand our horizons about how we viewpoint
sources. This is another example of a point source. We\'ve got a small
probably one, one‑and‑a‑half inch spigot and once the water drops onto
the ground it goes through a storm drain and into a navigable water.
Well, this spigot itself, then, is a point source. Here is another
example of a point source that we sometimes see working near waterways,
and that\'s a front‑end loader or any type of heavy equipment, and the
bucket itself here is considered to be a point source if it\'s
discharging pollutants into waterways. This next image is, again, rather
strange. You can see we\'re back to this same lake because it has so
many illustrations to it. You can see the water coming down into the
lake which is the make‑up water for the lake and the make‑up water
actually comes from this contreat structure, which is hooked up to the
potable water supply for the city. You could actually drink this water,
it\'s the same water that\'s put through the pipes for domestic water
supply. But it contains pollutants. It contains chlorine. It contains
fluoride. It contains other types of water pollutants. So in order to
have this discharge, there has to be a ‑‑ an NPDS permit for that
particular source. Lastly, I wanted to show you this firing range, and
this was kind of new information to me from Frank that I hadn\'t thought
of before and didn\'t have any particular knowledge about, but this is a
firing range, and there are some court cases that describe how a firing
range, because of lead and because of other pollutants that can come
from them, can be point sources. So if you have questions about that,
make sure to ask Frank about that as we go along here. Now, any water
that\'s going to be discharged from a point source into waters of the
U.S. has to have a discharge permit or an NPDES permit. These discharge
permits require lots of different things, but typically they involve
discharge limitations, in other words, how many pollutants and what
quantities you can discharge. They require certain monitoring
requirements and reporting requirements. They sometimes can be quite
complex. So at this point, if you have any questions about NPDES
permits, please be sure to ring in on your push‑to‑talk. We would be
glad to cover those. While we\'re waiting for questions, I would like to
cover a couple other minor aspects under the Clean Water Act that we
thought we ought to introduce you to. The first one is the concept of
water ‑‑ storm water discharge permits. Storm water discharge permits
are a type of NPDES permit that\'s required from municipal and
industrial activities. Now, normally Federal land management agencies or
not involved with these types of activities, but a lot of your wareyards
and other facilities are located inside municipalities and those
municipalities may have to have a water discharge ‑‑ storm water
discharge permit, and your activity may have to come in compliance and
be a part of that permit. The other storm water permit activity that you
might need to be aware of relates to the clearing of land. If you have
an area of one acre or more that you\'re going to clear, then you have
to have a storm water permit for that. And one acre is not very much. So
it doesn\'t take much to have that particular permit requirement.

\> The last aspect I wanted to mention to you relates to the
pretreatment program. In many cases, wastewater treatment plants require
industrial dischargers to pretreat their wastes prior to discharging
those wastes into their wastewater plant, and so you should be aware of
that. Times we think only in terms of large wastewater plants ‑‑ let\'s
see if we\'ve got one here. But a lot of times the dischargers can come
from smaller dischargers, such as doctors\' offices and dentists\'
offices. Anyway, that\'s a brief rundown on the wastewater pretreatment
program. Here in this visual you see a Federal wastewater plant that may
be subject to the pretreatment requirements. I think with that, that\'s
a real brief overview of some of the major attributes of the Clean Water
Act to kind of give you the overview of it. Again, I invite any
questions about that, but right now what I would like to do is turn to
Karl. He\'s going to talk about another type of discharge permit called
a dredge and fill permit, or 404 permit and then TMDLs ‑‑

Caller: I have a question about the water discharge permit. It says a
storm water permit is required for clearing, grading or otherwise
disturbing more than 5 acres of ground and I believe you said one acre.

M. Thrasher: Good question. I\'m glad you asked that. That rule was 5
acres for many, many years. It was recently changed to 1 acre. Thank
you. Karl?

K. Gebhardt: Thanks, Martin. One of the thing that we\'re going to be
talking about is 404 permits and then after that TMDLs. I think the last
question brought up point that these regulations change pretty quickly.
So it\'s important to keep track of them and move forward with going to
the websites finding out what actual permit ‑‑ websites and finding out
which permit will apply to your particular area. 404 discharge permits
essentially are applicable if you are going to discharge just about any
kind of material in a water of the United States or wetland. And let\'s
take a look at some of the things that are covered under that. Dredge
and fill permits are administered by the corps of engineers for the
Environmental Protection Agency. Essentially the regulations are
duplicated in two parts in the CFR, parts 40 and parts 33, both that
cover the EPA and the corps assignments. Some kind of a permit is
required for dredge and fill activities in navigable waters. There are
two types of permits you should become familiar with, individual permits
which deal with other than nationwide permit actions are kind of like
really complex things. Nationwide permits, on the other hand, deal with
actions that are fairly routine and are likely not to cause water
quality problems such as stream restoration, maintenance and things like
that. I think if we go to some photos, we can maybe illustrate some of
these things. Here\'s a typical mine drainage situation. Now, under the
404 permit, if you were thinking about doing any dredge and fill
activities in this water or adjacent wetlands, the first question you
need to ask is: is it adjacent to or supplied by some major navigable
water? If it is, then you\'re required to get some kind of a permit.
Just recent legislation ‑‑ excuse me ‑‑ recent court finding found that
now the old interpretation of navigable waters changed a little bit. So
if ‑‑ for example, this water doesn\'t go anyplace, if it\'s isolated
from a navigable water, and I was to do anything within like the wetland
zones, I would be exempted from requiring a 404 permit. This is a really
major change since up to about six months ago. Another area that you may
be involved with, particularly as Federal managers, is doing stream
restoration work. This particular stream may undergo several kinds of
changes. One is just a vegetative change and if you are just putting
vegetation into the stream corridor, stream banks and so forth, you
likely are not going to be involved with any kind of 404 permit. But
often times when you\'re doing stream rehabilitation, you\'re doing work
within the water system itself, and maybe along the wetland by the
placement of other materials or fishery structures or things like that.
If you are dealing with that, you need to at least talk to the corps to
find out if a permit is applicable. In this particular case, if I was
doing a stream structure, I would probably be covered under a nationwide
permit. Unfortunately, about middle February, the nationwide permits
expired for all of the United States. In about four days the new
permitting actions are going to come forward and they will involve some
new things that you\'re going to have to be familiar with. One of those
things has to do with conditions. Now, the previous slide I would be
doing restoration work, and normally you would be ok to do work under a
nationwide permit. And one of the things now that\'s different from that
is that the nationwide permit will not apply to fishries in the Pacific
northwest and this is not uncommon to the corps of engineers
regulations. What they tend to do is put condition Oz various nationwide
permits that are different from corps district to corps district. So
it\'s important that you contact your local corps to find out exactly
what kind of permits and conditions are applicable. Let\'s take a look
at another situation. This would be if you\'re trying to control bank
erosion. This is an old, old application of a pretty poor technique, and
it certainly isn\'t a best management practice, filling a bank like this
would probably be prohibit nowadays. You can see that these blocks of
concrete and rock go down into the water, and the corps\'s principally
interested in the mean high water and that\'s what their regulations are
written to control, and also wetland. So any kind of deposition of this
material or similar material would require a 404 permit. Another
application might be for corridor restoration would be the application
of mulch. Under normal circumstances, if you\'re not going below the
mean high water mark or if not in a wetland, you probably wouldn\'t need
a permit. But if you are going below the mean high water mark, then you
would need a permit for something like this. One other major change
that\'s happened within the 404 permitting process is the work within
ephemeral channels and this will vary from corps district to corps
district but in a lot of cases now, ephemeral channels are excluded ed
from 404 permitting processes. So again you have to be a little bit
careful, but just understand if you are planning to put things in the
stream, talk to your corps of engineers folks and they can help you out
with things. Thumb things that will help you and this is after talking
to one of the corps supervisors that are in charge of the 404 program,
they said it would be helpful if the Federal agencies could hold annual
meetings with them, particularly in the wintertime, to go over project
needs they might have. This gets sense, the corps gets extremely busy in
the spring and summer with projects. If you do have questions and want
to check out current regulations and changes, check out the website
that\'s shown on your screen here, and they keep a very good set of
links to all the corps district offices with addresses and contacts and
things like that. Now we\'re going to change gears a little bit and look
at total maximum daily loads. TMDLs are an area where a lot of Federal
agencies are starting to work at, and it\'s consuming a lot of time
it\'s definitely one of those areas if you haven\'t been familiar with
it, you certainly are getting educated quickly, but for those of you who
might be familiar and maybe unfamiliar, I\'m going to go over some real
basics of the Tim bill to give you a ‑‑ TMDL to give you a headstart.
The first thing to be aware of is there is a requirement within the
Clean Water Act that has to do with identification of streams that
don\'t meet state water quality standards and these streams are called
section 303 (D) listed streams. Oftentimes you\'ll hear the terms 303
(D) list. This is what this section refers to. That list is established
about every two years, and it lists those streams that have been
identified to not quite meet water quality standards. We call those the
list of impaired waters. The Clean Water Act also set priorities for
TMDL development, and TMDLs are set up to try to help these listed 303
(D) waters meet water quality standards. So a TMDL needs to be
established for each pollutant and ‑‑ on each water that is listed on
that list. Let\'s take a look at some of the recent listings and see how
they have affected the United States. This is a map of the United States
by subbay sin, and the bay sins that are listed in the red have
essentially 25 waters or more that do not meet water quality standards.
So these are high priorities within the system to get something done.
Well, over the last few years, people have been looking at these lists
and have ‑‑ are under the opinion that maybe the states and perhaps EPA
aren\'t moving quite fast enough. So with that said, a number of
lawsuits started cropping up, and to date I believe that we\'ve got
about 39 or more lawsuits involving TMDLs across the country. So what is
a TMDL exactly? It is amount of pollutant that a water body can receive
and still meet water quality standards. This may limit the use of
Federally managed lands. So you need know what is written in the TMDL.
Exactly where and how much of that is determined is in the TMDL process
itself and you can find out information on this by accessing the website
shown on your screen at epa.gov/owow/tmdl. Three steps to the TMDL
process include assessment, loading analysis and implementation plan.
The basic TMDL procedure will vary a little bit from state to state but
generally it follows this procedure and looks at the subbasin as the
first step in figuring out what to do. The loading analysis and loading
application will be completed in each pollutant that is listed on the
stream, and then hopefully an implementation plan will be developed to
try to bring the waters back into water quality standards. Let\'s take a
look at some examples you might run into that fit these three steps.
First of all, cooperation is an important step in the process. Federal
agencies are required to participate in the process. However, the amount
of participation and whether or not you may actually help prepare the
TMDL will depend on your decision. If your agency has significant water
resources, you may be ‑‑ want to be involved very heavily in this
process at a very detailed level. After that\'s done, we move into a
determination of what is actually coming off the watershed within the
water, and this requires some sampling. So the loading determination
will be done as a part of the analysis, and it\'s only ‑‑ is good as the
data available for that particular pollutant that caused the 303 (D)
listing. In my experience, good data yields good decisions supporting
sampling wherever possible. The third areas is the TMDLs will look at
existing practices and we want to get away from using the same old kinds
of processes we have done in the past and we want to look toward
processes that are called best management practices, and these practices
are actually things that have been noted by the water quality management
agency that helps them meet water quality standards. So what you want to
do is try to use these best management practices to bring your water
into compliance. And, finally, we want to move into the monitoring phase
and monitoring can be an extremely important part of this whole process.
Without good data, as with in just trying to figure out what the problem
is in the first place, you won\'t have a good defense in case your
particular water happens to go to litigation. Without good data, you\'re
not going to be able to properly adjust your management. So with that
said, a few things that you might want to consider when you\'re actually
dealing with a water quality management agency, kind of these shall the
bottom line things that you want to consider. Cooperate with the water
quality agency as best you can. Help them to identify those areas that
might have identified or limited waters, and work in your plans to try
to deal with those waters. So if you already have them covered in the
land management plans, that\'s great. If you don\'t, you ought to take
some steps to build things into your plans to help accommodate
improvement in water quality. Use approved best management practices
wherever possible, and then get into a system where you\'re monitoring
your activities and actually looking at the listed pollutant to see if
they are meeting the standards or not. The final thing that we\'d like
to take a look at is around the corner there are some other situations
that are going on. One is the TMDL rule somebodying revised, and the
effective date for the new rule is going to be April 30th, 2003. Now,
that may slip a little bit, but, again, I\'ve put up this website
before. Take a look at that, and that should help you. Move towards
understanding and participating in the TMDL process. Other things that
you might want to consider in the future is. , again, getting in close
contact with your water quality management agency or EPA, if the state
isn\'t in charge of your program, and getting a good working
relationship with those folks. They have a lot of waters to assess and
if you can get very familiar with their field people and maybe help them
in the assessment, it will be a really good step towards making some
headway if this really complicated issue called TMDL. With that I would
like to turn it back to Martin to continue the discussion.

M. Thrasher: Thanks, Karl. I want to ask if there are any questions at
this point if you want to use your push‑to‑talk, ask Karl questions or
me questions about the Clean Water Act, we would be glad to take them
before we turn to the Safe Drinking Water Act.

Caller: This is Bob from Coos Bay. I would like to know if there is any
more other than lead contap nation with the firing ranges, like maybe
mercury or something like that?

M. Thrasher: Frank, did you hear that?

F. Mills: Right now the principal contaminant of issue in a firing range
is the lead. But there has been some talk of the pollutants that are
coming off of the cartridges that are left on site, burnt powder
residues have high nitrates in these them and these are also showing up
in some testing. So a management practice of collecting cartridge asks
placing them in containers into help alleviate that, but principally the
court cases have dealt with the lead issue, and then the next thing that
they\'re starting to look at are the petroleums that are bound in the
targets that are shot out during shotgun sessions. These targets have
high petroleum content and are kind of a bound petroleum mass and
particulates bound together. So they\'re starting to look at that now as
an issue also.

M. Thrasher: I\'m glad you mentioned the nitrates. I\'ve been involved
with firing ranges where they\'re not only shooting your shotguns, your
rifles, your pistols, but they double up and they allow law enforcement
to blow up bombs, pipe bombs, illicit munitions of various kinds and
over a period of 20 or 30 years, you can get quite a nitrate buildup
from that, and you may end up doing a cleanup of the nitrates at some of
these sites. Good question.

Caller: Thank you.

M. Thrasher: You bet. All right. If you have any other questions, make
sure to ask. What I would like to do now is give a brief overview of the
Safe Drinking Water Act. It again is another one of these that\'s
delegable to the states. You are going to see state involvement
primarily. The purpose of the act is control. Contaminants in finished
water or potable water provided through public water systems. And it
does this by establishing primary and secondary water standards to
protect public health and welfare. There are actually four different
types of water systems that I want to briefly introduce you to, and not
in any detail. The first relates to community water systems. This system
serves at least 15 ‑‑ at least 15 service connections used by year‑round
residents or regularly serves at least 25 year‑round residents. And then
the counterpart to that is your noncommunity water system, and that\'s
any water system that\'s not a community water system. So you\'re either
one or the other. Now, within the noncommunity water systems we have two
different types. One is called transient and the other is common
transient. The transient is the system that does not serve 25 of the
same nonresidents per day for more than six months of the year, and then
the non transient is the noncommunity water system that serves at least
15 service connections used by travellers or intermittent users for at
least 60 days. Now, I know I\'ve gone through those really quickly. ,
but the point of this is that if you\'re operating community water
systems or noncommunity water systems, you need to look at the specific
rules for those systems and follow them religiously. As far as the
scheme for the regulation of these things, the Safe Drinking Water Act
sets maximum primary maximum contaminant levels to protect human health
and then the secondary maximum contaminant levels for the aesthetics.
That\'s a real quick rundown on the Safe Drinking Water Act. I
understand, Frank, that the Forest Service operates a number of
community or perhaps noncommunity water supplies. Maybe you have some
thoughts about that.

F. Mills: As many of you know, our agencies, including the Forest
Service, are one of the largest suppliers of water to the public in the
United States. One of the things I would like the managers to be aware
of is that the record keeping burden for maintaining a water system is
very, very onerous and very important, and one the largest violations
that we see in the field is failure to keep proper records. Another
issue that we\'re dealing with in the field constantly is that we are
turning maintenance and record keeping and reporting requirements over
to concessionaires or permitees, and if you have a system, for instance,
say a Boy Scout camp, that is serving four to 500 children per summer,
and you\'re allowing them to take the samples and make the reporting
requirements, you need to constantly monitor to ensure that the water
the children are receiving in that camp is actually good water and that
the processes that the camp is using to collect the samples are actually
right. One of the worst things that we can do as a public agency is
provide bad water to the public, and all of you know when you go to a
spigot and you turn that handle, you expect the water to come out to be
drinkable water, and we have a burden to ensure that the water we\'re
providing the public is drinkable water, not only those systems that
we\'re maintaining ourselves but systems we\'re allowing permitees,
concessionaires and other people to maintain that we actually have
management oversight of. Karl, do you have anything from the BLM ‑‑

K. Gebhardt: One of our systems or problems are similar to yours. I
think the reporting requirements have been in the past one of the things
that we all fall down on and we need to do better. I think that if you
could have a few really important areas to focus on, that would be
maintenance responsibilities, making sure you have all the stuff picked
up around wellheads and things like and that that your treatment systems
are operating properly and that you are going through some kind of a
routine maintenance record keeping and sampling program.

M. Thrasher: Not only do we have liability and responsibility to comply
with the rules, but if for some reason somebody got sick because they in
gested drinking water from one of your facilities, there\'s civil
liability that attaches to that as well.

F. Mills: Right. There\'s that famous case in New York in the county
that had ‑‑ that small child had drank the water at the county fair and
the county was held liable for that.

M. Thrasher: All right. Let\'s turn to one other aspect under the Clean
Water Act this time, and that relates to spill planning. The Clean Water
Act requires that certain facilities develop what\'s called a Spill
Prevention Control and Countermeasure Plan, or SPCC plan. , if they
store certain quantities of petroleum. Now, the petroleum planning
quantities, or planning volumes, are if you have a facility that stores
underground more than 42,000 gallons of petroleum, or above ground, more
than 1320 gallons, or any container above ground has more than 660
gallons, then you have to have an SPCC plan. I\'ll never forget several
years ago I was representing a client and they had notified me, it was
actually a municipal client, and they had notified me a hospital in town
had released about 14,000 gallons of fuel oil from their back‑up
generators. They stored about 60,000 gallons of fuel oil to run their
electric back‑up generators for the hospital and unbeknownst to them,
they had lost about 14,000 gallons of this fuel oil down a stream. Well,
as soon as the ‑‑ it was found out who was missing the fuel oil, a group
of about 20 people, including the Coast Guard, the onscene coordinator
from region 8 in Denver, the city officials, fire officials formed at
the hospital, and after we had gotten done doing the obligatory
introductions around the table, the first thing the EPA onscene
coordinator at the hospital asked was can I see your SPCC plan. I\'ll
never forget the response from the hospital engineer. He said, what\'s
that? Not a good answer. The SPCC rules were first adopted in 1973.
They\'re 29 years old now, and the regulatory agencies are not
interested in hearing that people don\'t know what the requirements are.
Basically the SPCC requirements are that a plan has to be prepared and
signed by a licensed professional engineer, and there are very detailed
requirements for these plans. Fortunately, EPA has put out a format for
these plans, and if you follow the format, you should be in really good
shape for the plans. Now, the plans have to be available onsite if EPA
or one of the regulatory agencies ask to see them. You don\'t have to
send them in anywhere, though. As far as what needs to be included in
plans, you have ‑‑ for the above ground storage, you have to include the
volume of all of the containers. It used to be people were just
concerned about the very large contain herbs, like the several hundred
gallon containers and then they would include the 55‑gallon drums, like
these that you see here in this visual. But now folks are also include
the smaller containers, including the 5 gallon containers and then you
see over here some of the smaller quart gallon pint size containers. So
in calculating that 1320 gallons, you have to calculate the volume of
all of these containers. Now, here is another image that\'s probably
more typical for above ground storage and you need to calculate the
volume of these. Now, I\'m not positive, because I don\'t know the
exact, but I think that these are probably about 500 gallon tanks for
petroleum products. So youch\' got about a thousand gallons here on the
front, and then you\'ve got what looks to me like a couple more in the
back, which would bring it up to about 2,000 gallons of above ground
storage at this facility. That is over the trigger and they would
require an SPCC plan. Here is another visual that I hope brings up kind
of other thoughts about spill planning. This is a boat ramp. You can\'t
see any storage banks here, but undoubtedly there\'s fuel oil storage
someplace at this facility. It may be in underneath the boat talks here.
It could be back here at a remote location in the trees. We don\'t know.
But if there\'s petroleum storage there, under ground, above 42,000
gallons, or above ground buff 1320, they would need to have a spill
plan. If you have any questions about the SPCC plan requirements, please
push to talk and we\'ll be glad to answer those questions. I did want to
mention one other thing that\'s kind of related to the SPCC plans. The
Clean Water Act requires spill notification that\'s immediate to the
national response center. If you discharged oil or petroleum into a
water of the United States that caused a sheen or this kind of rainbow
effect on the water. They also require a notice for about 300 other
types of hazardous substances. Now, this reporting is in addition to any
reporting that\'s required under CERCLA or under the community right to
know laws. So as managers, you need to nope just because you comply with
reporting requirements under one regulation doesn\'t mean you\'ve
satisfied the reporting under the other regulations. So when you put
your management systems together to make sure you\'re doing reporting,
you need to consider all of these types of reporting requirements. I
think with that, I\'ll see if you guys have any comments about that or
if we have any questions before we turn to Environmental Justice.

F. Mills: While we\'re waiting for questions, the definition of oils has
changed also, and you might be interested to note that vegetable oils
are now included in the cumulative total of all oils. So if you\'re
using a peanut oil or a ‑‑ you have a large food processing facility,
say a dining hall for a large scout camp or a youth group, they could be
maintaining a large quantity of vegetable fat oils on hand and that has
to be counted as part of your 1300.

M. Thrasher: Thank you. Are there any other questions or comments about
the Clean Water Act, Safe Drinking Water Act? We\'re going to have
another opportunity at the end ‑‑

Caller: This is Janet with the National Park Service. Can you tell me
how the TMDL rule affects the safe drinking water standards?

M. Thrasher: Can you address that?

K. Gebhardt: Sure. The TMDL rule really wouldn\'t be doing anything to
the drinking water standards. The TMDL addresses sort of all the
pollutants that fall under the Clean Water Act. The Safe Drinking Water
Act standards are apart from that. But if there are situations where you
have water quality standards that are being violated, then that\'s where
the TMDL would want to come in and make changes in the management or
whatever whatever that\'s causing the problem, and it might be related
to a system that is supplying a water quality situation ‑‑ or a drinking
water situation, like a municipal watershed or something. Source water
protection is one of the areas in the Safe Drinking Water Act that some
agencies are going to start getting into in the future that addresses
this.

M. Thrasher: Yes. I kind of think that that\'s probably where the tie
is, because under the Safe Drinking Water Act, many of the larger public
water supplies have to have a program for source water protection which
means they have to figure out how to protect the source of the water,
which could be surface waters, and those service waters are impacted by
TMDLs. So I do think there is a relationship. I don\'t know exactly how
it\'s going to play out, though. Good question, though. We\'re going to
have another question and answer period here at the end. I wanted to
finish the program today with a discussion of Environmental Justice.
Environmental Justice, it was the subject of an Executive Order 12898 in
1994 and it had three primary purposes. It was to focus Federal agency
attention on human health and environmental conditions in minority and
low‑income communities. It also sought to foster nondiscrimination in
Federal programs and to give minority and low‑income communities greater
opportunity for public participation and I think the best way to get a
sense of what Environmental Justice is about is through a video that we
have available and I think we\'ll go ahead and show that now.

What is Environmental Justice? Why is it important? And what does it
mean to you as someone in the environmental field? I\'m Dennis. These
are some fundamental questions facing us today. Here are three experts
to help us address them. (Speaking foreign language.) (Speaking in
Spanish.)

My agency views itself as a crossfunctional change agent implementing
increasingly complex benchmarking paradigms of Environmental Justice.
The synergy among NEPA, CERCLA, FLPMA and RCRA creates a cost effective
TQM initiative utilizing public, private preventative approaches to the
equitable distribution of positive and negative external Al tease
regarding human ‑‑

You probably understand very little of what you just heard. In fact you
may have felt a bit frustrated, angry or excluded. This is how other
people may feel when they try to understand and participate in your
projects and programs. So what is it Environmental Justice in
Environmental Justice is achieved when everyone, regardless of race,
culture or income, enjoys the same degree of protection from
environmental and health hazards and equal access to a healthy
environment in which to live, work and play. Keeping in mind this
definition of Environmental Justice, we\'d like to examine some
misconceptions surrounding this issue. Low income and minority
communities have chosen to live near environmentally degraded or
hazardous areas, therefore it\'s their problem and not ours.

This view ignores that our laws are written to protect all of our
citizens. Also these so‑called choices are often predetermined by
economic realities.

Environmental Justice is a new issue.

Environmental Justice links traditional, social and constitutional
issues with the environment. Existing laws, such as the national
environmental policy act, and the Resource Conservation Recovery Act,
support Environmental Justice in their public participation and in their
implementation.

Environmental Justice is more work and will slow me and my project down.
If properly done, including minority and low‑income communities can make
your job easier. Your project more successful. And end up saving you
both time and money.

Environmental Justice is something you do for others.

No, Environmental Justice is something you create with all parties. As
Jane Addams said, the good we secure for ourselves is precarious and
uncertain\... until it is secured for all of us, and incorporated into
our common life. It is important that we not waste our time pointing
fingers at past actions or decisions. Instead, let\'s use our
understanding of the past and our existing resources to create
solutions. So let\'s start from the beginning. sue, would you give us
some background on the origins of the Environmental Justice movement?

Well, the Environmental Justice movement came about as communities of
color and low income communities began to realize that their
neighborhoods were being chosen disproportionately for the siting of
environmentally undesirable facilities. These communities felt excluded
from the siting decisions and the operational decisions relating to
these facilities. In addition, they had health and safety concerns that
they felt weren\'t being taken seriously. And finally, they began to
feel that environmental health and safety laws were being unevenly
applied and enforced.

What is the basis for these concerns?

Well, these concerns are very well documented. We know for example that
3 out of 4 hazardous waste facilities in this country are sighted in low
income communities and communities of color. You pair that information
with the fact we have 8 million inner city kids covering from lead
poisoning? Is there a connection? You can bet many people believe there
is. In rural areas we have 2 million tons of radioactive waste stored on
tribal lands. We also know that Navajo teenagers suffer from
reproductive cancer at 17 times the national average. In terms of
enforcement we have seen that penalties for hazardous waste violations
in white common tease are 500% higher than in communities of color. Of
course, the main basis for the concerns is the experience of the people
in these communities, which leads them to believe that their health and
safety are at risk from environmental conditions in their neighborhoods.

Eduardo, as we\'ve seen, there have been a lot of recent changes, such
as the president\'s Environmental Justice Executive Order of 1994. How
will this Executive Order affect how we do business?

Well, under the Executive Order, agencies must make Environmental
Justice part of their mission. Right now we\'re still not sure how far
the Executive Order is going to change the way we do business, but, for
example, on the resource conservation recovery act, the scope of public
participation has been expanded.

Tell us some specifics about the Executive Order.

Well, under the Executive Order, Federal agencies must make sure that
their activities do not exclude any one from participation, deny the
benefits of those activities to any person, or to subject any person to
discrimination. In ordered to this, agencies must first identify and
collect demographic information about the areas surrounding their
activities. You need to include populations you\'ve identified in your
decision making, and you also need to compile information about the
health effects of your activities, including information on subsistence
consumption of fish and wildlife.

How will the Executive Order be implemented?

The Executive Order will be implemented through agency strategies which
will direct Federal employees into incorporate Environmental Justice
into everything that they do. Currently there are organizations like the
national environmental policy act and land use plans. For example, if we
take an action which will have an effect on a traditional ceremony of a
native American tribe, we must consider such an impact under the
Executive Order and NEPA.

How does the Executive Order relate to existing civil rights laws?

The Executive Order reaffirms our commitment to the equal protection
guarantees of the constitution. It merely restates title 6 of the civil
rights act which requires that no person shall be excluded from
participation in, denied the benefits of, or subjected to discrimination
under any program or activity receiving Federal financial assistance.

What should we keep in mind when considering Environmental Justice?

Environmental Justice is a question of basic fairness. We need to ask
ourselves if our actions are having different impacts on different
communities.

Don\'t forget, Environmental Justice isn\'t about agencies, it\'s not
about environmental groups. It\'s about communities taking control of
the environmental problems and the environmental opportunities in their
lives. So identify these communities and include them in your decision
making.

Jean, tell us how the national environmental policy act can be an
important tool for Environmental Justice.

Well, first off, I should say that I think the national environmental
policy act, NEPA, is one of the most insightful and progressive pieces
of legislation Congress has ever passed. The purpose of NEPA is to
promote better public decision making and even though it only applies to
Federal actions, it\'s really about people and their relationship to the
environment and to each other, and one of the principles that it was
always meant to address is that of Environmental Justice. As section 101
of NEPA states, Congress recognizes that all Americans should enjoy a
healthful environment and that each person has a responsibility to
contribute to the preservation and enhancement of the environment.

Patrick, tell us what low income and minority communities are looking
for in public involvement.

They\'re looking for several things. First off, they\'re looking for
access to decision makers, and early and frequent access to the decision
making process. They\'re looking for community and tribal based
solutions to environmental problems. That includes the health and
protection of the children and families in their communities. They\'re
also looking to us to help them look at big picture problems in their
communities and not break their communities up into small segments or
components. And last, I think most importantly, they\'re looking for
open and honest communication.

How can we mitigate our impacts on communities?

There are several things that we can do to mitigate our impacts. We can
do self‑examinations of what we do and how we do it, and specifically,
how that affects low‑income and minority communities. We can provide
easy access points to communities that want to come in and utilize our
expertise and our information. We can streamline our internal processes
so that they\'re easy and user‑friendly for residents and communities
that are affected. We can do outreach to work with communities on
projects that build good will and strong support. We can also bring
interested parties together to build strong coalitions and develop good,
sound solutions.

What can one person do to further Environmental Justice?

The key is being proactive. You are the best ambassador for your agency.
All communities respond very positively to being treated with respect
and dignity. Any strong lasting relationship begins with small steps.

Lorraine, would you share some of your insights about how to work
successfully with minority and low‑income communities?

First, it\'s important to remember that the people that live and work in
these communities are experts in their own right. They have much to
share. Secondly, developing partnerships is important. Partnerships that
are based on mutual respect, a willingness to learn and share decision
making. We do share a common goal. If we can work together as allies, we
can achieve that goal to the benefit of all of the people involved.

What are some specific community involvement approaches that you\'ve
found helpful?

We\'ve worked on three superfund sites. What we do is we take the
information that\'s available, we translate it into community language
and then we hold public meetings with people, residents, can come and
hear the information so that they can understand what\'s going on. We
also create opportunities for people to be involved in the decision
making. Tactics we\'ve used include door knocking, translating
information into Spanish, offering interpreters at public meetings and
baby‑sitting at public meetings, and asking for extended public comment
periods so that people have time to learn, understand and reflect upon
the information they\'ve been given. One important tactic has also been
to outreach to allies, such as the board of education or the housing
authority, who also have an interest in the site.

It seems like lot of work. What are the benefits of these approaches?

It is a lot of work. It\'s an inherent part of the process. But when
people work together as allies, as partners, the work can be shared, the
responsibility can be shared, conflict can be avoided, the process can
move more quickly, and we can have an outcome that is acceptable to all
of the parties involved.

There has been and continues to be unequal environmental protection and
lack of access to decision making process. However, we can change this
by doing the following:. Increasing our awareness, involving and
listening to all affected communities in every stage of a project or
program, using common sense approaches, as well as state of the art
technology, and being creative and open to new perspectives and ideas.
Now, we have the opportunity, and resources to make Environmental
Justice come alive. Working together, we can heal, protect and properly
manage the environment for all of us.

M. Thrasher: Ok. What you\'ve seen is an excerpt of the tape on
Environmental Justice. If you want to order the entire tape, you can get
ahold of Dennis SOHOCKI, and you can see the phone numbers there. For
the contacts, either in Arizona or Colorado. .

M. Thrasher: I think with that, Tony, we\'re to the place in the program
where we need to turn to the infamous \"HazMat Challenge.\"

T. Garrett: We\'ll do that. Let\'s first let our downlink sites we are
going to run a few minutes past our noon mountain standard time target
time for completing. We won\'t go much past noon, but we will be going a
few minutes past noon so that we can get in all the material and
particularly the game show, \"The HazMat Challenge.\" using the board on
your screen, our competing teams will take turns selecting squares, and
answering the question behind those squares. Answer correctly and claim
the square. The team to claim three squares in a row will be the winner.
Here is what you will be competing for in today\'s round of \"The HazMat
Challenge.\" It\'s the official, accept no substitutes, this is the
official \"HazMat Challenge\" T‑shirt. All right. Again, today everyone
east of the Continental Divide will be on Team East. West of the
Continental Divide will be on Team West. If everyone is ready, let\'s
play \"HazMat Challenge.\" We\'ll begin with a music sting. Let\'s start
with Team East. Anyone east from the east of the Continental Divide,
check in with us now.

Caller: This is ray at National Park Service.

T. Garrett: Go ahead and select a square.

Caller: 5.

T. Garrett: All right. Ray, the question is: the ambient air quality
program is implemented through emission limits contained in: is it tips,
SIPs or chips & dips? You have 10 seconds, ray. Don\'t blow this one,
ray.

Caller: Let\'s go with B.

T. Garrett: All right. Gets in under the wire with B. Nice going, ray.
Ray for Team East plants an X in the middle of the board. Let\'s go west
of the Continental Divide. Anyone from Team West check in with us now.

Caller: Peter from Grand Canyon.

T. Garrett: All right, Peter from Grand Canyon, select a square for Team
West.

Caller: Number 7.

T. Garrett: Peter, the question is, true or false, new sources of
pollution are subject to the same permitting requirements as existing
sources of pollution. Peter, you have 10 seconds.

Caller: That\'s false.

T. Garrett: All right. Peter says false, and the correct answer is?
False. Nice going, Peter. And Team West claims square number 7. Let\'s
go back east of the Continental Divide. Anyone from Team East?

Caller: ‑‑

T. Garrett: Worland, hold on and let\'s go to Arlington, Fish

&

Wildlife Service.

Caller: Can I get 9?

T. Garrett: Ok. Square number 9. The question is: what does TMDL stand
for? Toxic material data list, total maximum daily load, total minute
MUP daily load.

Caller: It\'s B, total maximum daily load.

T. Garrett: Nice going. Fish

&

Wildlife Service representing Team East on that one. They get a correct
answer, and is threatening with an X in square number 9. Back west of
the Continental Divide, Team West check in with us.

Caller: Hi, this is Terry from Carson, Nevada.

T. Garrett: Hi, Terry from Carson, Nevada. Select a square if you would,
please.

Caller: 1 please.

T. Garrett: True or false, the final TMDL is submitted to the state DEQ
for approval. You have 10 seconds, Terry.

Caller: We\'re going to say false.

T. Garrett: Good going. What\'s the correct answer? It\'s false. Terry
in Carson for Team West blocks that bid by the east. Let\'s go back to
east and see what strategy east comes up with.

Caller: This is Worland again.

T. Garrett: Go ahead.

Caller: We\'ll take number 4.

T. Garrett: 4 to block. The question is NAAQS stands for? Is it national
air attainment qualification system. National airborne applications
query system? National Ambient Air Quality Standards? Worland, you have
10 seconds.

Caller: Number C.

T. Garrett: Indeed the answer is C. Team East puts an X in square number
4 to block that attempt by the west. Nice going Worland. Let\'s go back
west of the Continental Divide now? Anyone west of the Continental
Divide, check in with us.

Caller: Potter at Grand Canyon again that if nobody else will.

T. Garrett: Peter, go right ahead.

Caller: 6.

T. Garrett: All right. Peter, number 6 is a storm water permit is
required for clearing, grading or otherwise disturbing more than ‑‑ is
it 1 acre, 5 acres or 10 acres? You have 10 seconds, Peter.

Caller: It\'s A., 1 acre.

T. Garrett: All right. This is correct. Peter representing Team West
puts an end to that effort by the east. Let\'s go back east, east of the
Continental Divide. Anyone from Team East.

Caller: Lamar, big thicket.

Caller: Kim, Fish & Wildlife.

T. Garrett: Fish & Wildlife hold o let\'s let Lamar select a square. Go
ahead, Lamar.

Caller: You\'re up Lamar. Select a square.

Caller: 3, I guess.

T. Garrett: The question s the Clean Air Act has a goal of eliminating
all man made visibility impairments in ‑‑ is the answer 10 years, the
western hemisphere or mandatory class 1 areas. Lamar, you have 10
seconds.

Caller: Try C.

T. Garrett: Ok. Lamar says C., and the answer is C. Nice going Lamar for
Team East. Let\'s go back west. Anyone from Team West. Peter, you\'re
welcome to go ahead. We also heard today from Boise, Coos Bay, Albright,
Lakeview Oregon. Anyone from Team West, go ahead and check in with us.

Caller: This is Coos Bay, Paul.

T. Garrett: Select a square, please.

Caller: 8.

T. Garrett: The question is mandatory class 1 areas are mostly ‑‑ is it
industrial corridors, parks and wildlife refuges, or densely populated
urban areas? You have 10 seconds. We\'re going to have to consult with a
judge on this one.

Caller: C.

T. Garrett: Say that again, Paul.

Caller: I\'m going to go with C.

T. Garrett: I think Paul said C. but the real answer we have on the game
is parks and wildlife refuges.

M. Thrasher: That\'s kind of a poor answer because the wildlife refuges
are not called out as mandatory class 1 areas. So kind of a trick
question there, Tony.

T. Garrett: That was the best ‑‑ would you say that\'s the best of the
three answers?

M. Thrasher: That was the best of the 3.

T. Garrett: We\'ll have to take that up with the game show producers
when we catch them. Now let\'s go to Team West. Did we give Paul a
square on that answer? No, we did not. Team West, go ahead.

Caller: Team East.

T. Garrett: Team East? All right. Sorry about that. Team East, go ahead
and select a square.

Caller: We\'ll select number 2. This is Worland.

T. Garrett: The question is to true or false, the Safe Drinking Water
Act applies to underground injection wells and cleanup of CERCLA sites.
You have 10 seconds, Worland.

Caller: True.

T. Garrett: Worland says that\'s true, and the answer is true. Nice
going Team East. East puts a square in number 2. Hmm. I see. Thank you,
and Team East wins because they have five squares, I\'m told. Good. All
right. Well, that was exciting, albeit confusing. And all of our ‑‑
everyone who called in today will be receiving the official has mat
challenge T‑shirt and congratulations to Team East. That\'s the first
time we have had that phenomenon of winning without the three diagonal
or vertical or horizontal but winning with five squares. Very nicely
done Team East. And that stands now at two wins for Team East, three for
Team West and we\'ll see what happens, if anything happens n Module 6.
We\'re not sure whether we\'ll be back with that game or not. Each
caller will be receiving, as, as I said, the HazMat T‑shirt and to get
yours you need to send me an e‑mail so we will know where to send your
shirt. E‑mail me at this address. now we have reserved some time, a
couple minutes for questions you may have in today\'s broadcast. We will
keep the green light on, and we do want to hear from you and address any
questions that came up during the past three hours or so. Any of the
material we\'ve covered today, go ahead and push to talk or call in and
let us know what your questions are.

Caller: This is pat. Can you address where we can find the meaning of
cleared land? \...

T. Garrett: Pat, we\'re having some difficulty with that audio system. I
was not able to understand your question. So what you need to do is send
us a fax or e‑mail and we\'ll answer that question and get back to you.
Either off the air or on the air in Module 6. Any other questions from
any of our viewers at any of our downlink sites?

Caller: Stephanie Nash, Fish & Wildlife, Arlington square. It\'s not a
question. It\'s a comment. I would like to say I really appreciate the
time I spent with you guys and I really enjoyed it and it was very,
very, very informative.

T. Garrett: We really appreciate your letting us know that you found
some value in today\'s broadcast. Thanks very much for that comment. We
appreciate it. Any other comments or questions from any of our downlink
sites? All right. I hear someone keying a microphone. Any other
questions from any of our viewers? Ok. Let\'s take a moment, then, and,
Martin, I\'ll turn it back to you for a quick summary of what we covered
today.

M. Thrasher: The main thing I want to mention right now is the
importance of joining us next week. We\'re going to be talking about
management systems, how to try to tie this all together and start
thinking about how to manage all of our responsibilities. So it\'s going
to be a very important program. Again I invite you to bring to us any
management systems, any procedures, any policies that we can talk about
at the start of the program next week.

T. Garrett: All right. And that will complete Module 5 in our series,
the Manager\'s Tool Kit for Environmental Compliance and Pollution
Prevention. We hope you\'ll plan to be with us at the same time one week
from today, March 21st, for Module 6, our final broadcast in this
course. To let us know how many of you were with us today, please sign
the roster in your viewing room and fax it to us at this number. And
remember the primary source of information about this course, study
materials and resources will be on your agency\'s website. and we\'d
like to thank Martin Thrasher, Karl Gebhardt and Frank Mills for all
their great work in preparing and presenting today\'s material. On
behalf of the USDA Forest Service and the Bureau of Land Management,
thanks for watching, and so long from Phoenix.

Announcer: This broadcast has been a presentation of the USDA Forest
Service office of corporate training and the BLM National Training
Center.