3,12 VISION

Although most states will have complied with the letter of
the guidelines, in only a few states were the individuals
responsible aware of or planning to use the opportunities
made available by the guidelines (see section 3.5).
These opportunities include:

* using the process to further the state's own goal
of consistency among projections used by state agencies

* trying to develop consistency among the projections
used for federal programs

* articulating a growth policy via the projections

* conducting productive negotiations with substate
governments which might otherwise not have taken place.

It is our belief that a state seeing the guidelines as
something other than a.duli federal requirement was, in
part, dependent on prior experience in the agency or state
with making or using projections, one individual with a
particular interest in the "philosophy" of the use of
projections, or prior state formulation of or interest in
growth management or growth policy.

A major hurdle was that, as many states mentioned spontaneously,
they thought of this as simply another regulation and "don't
really understand what EPA wants" or whet problems EPA was
trying to solve in promulgating the guidelines.

Quite a few states already have or are working towards a
policy of consistent projections among all state agencies
(see section 3.6); in most of those, the states attempted

to use the opportunity of complying with EPA to foster that
policy. Some of them wentioned that this was not always

easy because of the conflicting requirements of other federal
or state agencies.

We are not trying to imply that had the option of not simply
preparing "trend" projections been mentioned to the states,
that lage numbers would have taken advantage of it. In

some states the question of growth policy is too controversial;
in others it is being debated but no policies have been
developed, One state volunteered that even had they

tealized the projections need not be "baseline" projections,
they would have prepared such anyway "because that's what
we've had experience with."

Although most states did not seem to realize it, it is oh
a political choice to use "trend" projections. It was the
lack of such awareness that, in our opinion, caused the t
poor attention to public involvement by most states (see

section 4,3). \



WISCONSIN

Date of contact: August 16

Randy Wade 1/77 wetimate: 4,651,000
Planning Analyst EPA project son: 5,553,000
Water Quality Penning Section State's projection: — vithin 52 of TPA
Departent of Natural Resources projectton eubmitted: sane

P.0. Box 7921
Madison, Wis. 53707
608/266-9265

State Projections

In 1974 the Department of Administration prepared three sets of projectsons
to 2000. The medium state cortrol total is within 5% of FPA. These seem to
he demographic projecttons.

Special Activities for EIA

Each areavide was given a regional control total —the sum of all ite comties.
They then did independent projections to minor civt} divistons and to

service areas, alt of which Luckily came out within the Department of
Administration's range. They then added up their own county totals which,
Wade says, are better than the Department of Administration's.

Agenctes used varying methods. One used an economic model. One used a
share model. The Milwaukee arcawide used a comJicated combined mode! which
Included a test using the “normative Land use plan. In at least one case
the projections were part of 208 plans.

In non-designated areas, there aren't always projections for all minor elvit
divisions, But vhere these have been done, they usually all vse the same
“share” or ratto mthodology -bared on the share which the diviston has
historically had of the county's population.

The numbers have not yet been submitted. Wade expected to meet the deadline,
but he doubted that the public participation requirement had been met yet.
Ne had not beard about it before our call.

The areavides have had Local citizens’ committees and meetings, but nothing
on the statewide level. Many of thene meetings, perhaps all, focussed on the
vhole 208 plan and not just projecttons.

The aremides Involved local communities in their projecting. There 1s 9
state population comet! that reviewed the projections. Environmental
Rroups have not heen involved except on local and statewide advisory boards.

Other Comments.

These projections will be the official state projections. Their use ts not
completed, but any plan that doesn't use them will be somexhat questionable
Apso facto. They will be used for water, alr, transportation, and most other
purposes.

The state used the population projections to prepare a twenty-year sewer plan
governing aJl sever facilittes and extensions down to A".

It soumds like the state is serlously committed to preparing and using
Projections.

wont
Date of contact: August 9

Phil Kiner 7177 estimate: 406 ,000
Diviston of Research and Statistics FPA projection: 484,000

DAFC (Dept. of Administratson & Tiscal Control) state's projection: ECA 4 20%
Room 302, Emerson Bldg. projection submitted: EPA + 20%
Cheyenne, WY 82001 or more

State Projections

Tals Division new produces population projections, having inherited the
responsibility recently {rom another agency.

Projections are prepared at the comty Jevel using an economtric and
demographic model; the state projection ts a sum. Trojections were txsued tn
November 1978 and July 1979 and are revined every six months.

Drafts of the projections are sent to cities and counties.

A Governor's memo requires other state agencies to ure these project tons.

Recause of commmications probleme, the Division did not find aut about the EPA
requirements until very recently.

The state's ow projection 1s approximately 20% greater than EPA's by the year
2000. The state is currently preparing the request for a variance For FPA.

Wyoming originally had three designated 208 apenctes, but two have dissolved.
Those two did have projections in thetr drafts.

If a public meeting is required, the state will comply. Mowever, this Division
does not usually schedule public meetings, and will probably work with the
Department of Environmental Quality.

Other Comments
Wyoming was one of the states which begen the process only recently. In order
to meet the October 1 deadline, the state vould have to have virtually Ho
notification for the required public meting. Perhaps if we had spoken
directly with the Department of Environmental Quality ve would have gotten a
clearer picture of vhat was Intended.

Wyoming's process of updating its projections every six months is the most often
in the country. Perhaps Wyoming and several other rapidly growing needs
need to vork out special arrangements with EPA.

-131-


K. Is the projection BEA used the most recent projection for
the United States.

Actually, it is not, but the differences are small. The Bureau
of the Census medium (Series II) projection for the year 2000,
issued in October, 1975, was 262,494,000. They updated the
projection in July, 1977 and this most recent projection gives
260,378;000 for the year 2000.

The BEA projections were released in early 1977 and began

with the earlier Census Bureau projection. However BEA also
took account of the acknowledged undercount in 1970 of more
than four million people. That explains why the BEA projection
for the year 2000 is several million people greater than the
Census Bureau's.

The projections above also include projections for the District
of Columbia, which is not discussed in this report. The BEA
lists a 7/77 population for the District of 690,000 and a year
2000 projection of 661,000.



ERRATA SHEET

A misprint was made in printing the cover of this report. The
title of this report should read:

A Progress Report: State Implementation of
EPA Guidelines on the Use of Population Projections

This report was prepared by the Sierra Club, 530 Bush Street,
San Francisco, California 94108 financed in part by a grant from
the Environmental Protection Agency. The contents do not
necessarily reflect the views and policies of the Environmental
Protection Agency.

Should you have any questions concerning this report, please
contact Cathy O'Connell, Environmental Protection Specialist on
(202) 755-8056.



SOUIN DAKOTA

Date of contact:

Jim Nelson 7/77 estimate 689,000
Deputy Piviston Director EVA projection: 730,000
Division of Water Managewent state's projectton: 797,000
Joe Fors Bldg. projection submitted: 77

Pierre, SD 57501
605/773-4523

Dick Gebhart
State Planning Bureav
State Capitol

Pierre, SD 57501
605/773-4599

State Projection

In Recember, 1978, the State Planning Bureau published a set of three projections
for the state through the year 1990. Using the same model, they have produced

a projection of 797,000, which corresponds to the Lavest of the three projections.

They begin with demographic projecttons at the comty level and sum to get a
state projection. The process vas overseen by an interagency population task
force.

Until January, there was a directive that these projectfons be used by all
te agencies, but the administration changed and that directive {s no Longer
in force.

Spectal Activities for EPA

The Division of Water Management has contracted with the State Planing Bureaw
to produce a projection for the year 2000. As of 8/27, the Jatter has not yet
formally sent Its work to the Division of Water Hamagenent.

Originally, the fatter had believed, based on an earller set of projections
done only through the year 1990, that the EPA projection was within the range
of the three official ones for the state. Nowever, If the Final State Planning
Bureau number 4s in fact 9% larger than the EPA number, as it appears to be,
the Division of Water Management will then have to consider whether to request
a variance ot simply use the EPA number.

Hr. Nelson expects the public meting to be combined with some 208 hearings.

Other Comments

South Dakota fs only naw beginning to consider how it will comply with the

guidelines. As a result, the results might be prepared on a rush basis without
adequate consideration.

TENNESSEL

Date of contact: August B

Toh Alexander, Chief 7/77 estimate: 4,299,000
Water Quality Planning Section EPA projection: 5,573,000
Tenmessee Division of Water state projection? within 5% of EPA

Quality Control
Department of Public Nealth
Sulte 309

Capltol Towers Buf lding

clo Jud hodney

Nashville, Tennessee 37219
(615) 741-2275

Projection submitted: same

State Projections
The State Planning Office disaggregated the “Bureau of Economie Analysis

1976 Series F population projections” to county, 201 area, nnd river
asin.

Special Activities for EPA

The Planning Office projecttons were included in 208 hearings held by
the Water Quality Control Division from mid-February to March, though
they were not emphasized.

-127-

The 208 plan containing the projections vas submitted by the Planning
Office on August IR, 1978, The state's disagpregations to facility
Planning reas are used for facility planning except In Memphis,
where the 208 agency had already developed thelr om projections.
Other Comments

We are in contact with a member of the 208 citizen's advisory committee,
who reports having been totally unavare of hearings concerning projec~
tons, Thin citizen's advisory committee, thu, does not seem to have
been an effective vehicle for public involvement.

There seems to be some confusion of responsibilities between the Planning
Office and the Water Quality Control Division.


Inadequacies

In quite a few cases, state staff with whom we spoke were
unaware of the requirement for a public meeting before the
disaggregations are submitted to EPA. To be fair, in some

cases we were speaking with staff of the "projections agency)
who defer to the environmental agency on such matters. On

the other hand, it is quite likely that in some of those

cases the environmental "person" regarded their responsibilities
as being simply to forward the projections to EPA. Further-~
more, in a few cases even the latter individuals admitted

to not knowing about the requirement for a public meeting.

In some states we believe the state meetings will be
virtually a farce for a number of possible reasons:

* The state is giving insufficient notice or not
announcing the meeting widely enough.

* Even after the state has given notice of a request
for a variance, no information will be available for citizens
to look at until a few days before the meeting itself.

* The meeting (in fact the entire process) is scheduled
so closely before the deadline that the chance of public
involvement making a difference, is virtually nil. But Florida
shows how a state, by starting early, can stimulate considerable
statewide involvement.

* The state does not want public involvement, sees it
as a nuisance which cannot contribute to their work.

One state in fact described its own public meetings as

"being done almost as an afterthought, without serious interest
in getting public involvement." Another state official said
he used to work with local governments and the public but
doesn't do that any more because he can produce better
projections than they can.

Furthermore, not only did some states hold these beliefs,

but they expressed them to a caller from the Sierra Club, whom
they might have presumed would have a great commitment to
public participation,

-74-


5.5 STATES WHICH HAVE HAD DIFFICULTIES

EPA should work particularly closely with those few states
which appear to have had or be having difficulty complying
with the guidelines, serious misunderstandings about them,
or problems developing a locus of responsibility within
the state.

We expect that if this is done, such problems will be sub-
stantially reduced, if not eliminated, by the time of the
next revision.

5.6 INVOLVEMENT OF OTHER STATE AGENCIES

(see section 4.1)

EPA should strictly enforce requirements for involvement of
state agencies and local governments. In particular, when
guidelines such as these require specific consultat.ton with,
for example, air quality planning agencies, EPA should

notify those state agencies directly to ensure they are aware
that their participation is needed.

This is particularly important for those states where the
projections are being prepared not by an environmental agency
but by a projections agency which might not appreciate the
desirability of involving others in state government.

-36-


LY
\

2.0 FLOW CHART FOR THE EPA PROJECTIONS GUIDELINES

Spectfic Opportunities for Public Involvement mirked with cross-hatching? Ws

FPA approves
F\ prose

or=

rete

Admin} \
1 FIA rejects

projections

—|.. back to |

-17-


APPENDIX 0
EPA CONTACTS

Listed below are individuals in EPA headquarters and regional
offices who can provide you with additional information about
the EPA requireemnts and particular states.

EPA Headquarters
Cathy O'Connell, 202/755-8253 or 202/426-9404 (leave message)
Facility Requirements Division (WH 595)
Office of Water Program Operations, OWWM
EPA
401 M Street, S.W.
Washington, 0.C. 20460

Region I (CT, MA, ME, NH, RI, VT) - Boston
Roger Duwart, 617/223-5130
Water Quality Branch

Region II (NU, NY) - New York City
Beverly Reith, 212/264-1340
EIS Preparation Branch, Water Division

Region ITI (DE, MD, PA, VA, WV, & OC) - Philadelphia
Gene Mattis, 215/597-3423
water Quality Management Coordinator

DE, MD, DC: Larry Merrill, 215/597-9966
PA: Rich Setzer, 215/595-9151
VA, WW: Hank Zygmunt, 215/597-8168

Region IV (AL, FL, GA, KY, MS, NC, SC, TN) ~ Atlanta
James Kutzman, 404/881-4989
Chief, Applied Technology Section
Water Division

Region V (IL, IN, MI, MN, QH, WI) - Chicago
Mary Lou Lageman, 312/353-2000
Regional Economist, Planning & Evaluation Branch

IL, IN: (Mr.) Noel Kohl, 312/353-2163
MI: dim Filippini, 312/353-2160

MN, WI: (Mr.) Oale Luecht, 312/353-2168
OH: Ed Watters, 312/353-2172

-137-


5.1 STATE ACTIVITIES TO INVOLVE THE PUBLIC

(see Chapter 4)

Unfortunately, it is not easy to spark overnight interest
in a subject like population projections that has long been
relegated to the private chambers of state demographers

and water quality planners. Whether or not they have done
so in the past, all states will now be required to prapare
regular updates of their projections, and the task of en-
couraging public involvement must be seen as a year to year
process to be built up gradually, not as something to be
attempted once and abandoned if not greeted with immediate
and spectacular outpourings.

Federal agencies overseeing state projections processes aust

give careful attention to formulating guidelines for insuring
state processes that genuinely attempe to involve the public,
ad are not pro forma displays.

These guidelines might include itemizations of procedures
for states to follow, but they should also contain the
flexibility co encourage state experimentation. In Section
4.3, Public Involvement, we listed some of the innovative
procedures used by various states to involve the public.

It might be noted that most of these procedures are also
highly effective in involving local governments and, in some
cases (e.g. Florida), state agencies that are not otherwise
involved.

We offer the following recommendations to states to facilitate
public involvement:

A. Written Materials on the State's Projections Effort

It would be extremely useful to the public, local government, and
others for states to produce a brochure on the results of the
state's projections work, describing not only the numbers and
the methodology, but also:

* who was involved in developing the assumptions

* how local governments and the public participated

* whether any state policies were included

* which federal or state agencies will be using the projections

and for what purposes.

The handbook being prepared by New York state is a beginning along
these lines.

-81-


ulations, the {inal regulations included
both revisions to the technical amend-
ments and editorial changes.

Altogether the Agency circulated
more than 60,000 copies of various
drafts of the regulations. We received
invaluable assistance from the organi-
zations, agencies, and the public at
jarge. Commenters raised a variety of
issues. The major Issues raised during
the official comment period are dis-
cussed below under the appropriate
subject area.

Various related regulations have
been or will be published soon. As re-
quired by statutory deadline, EPA
published two short amendments to
the construction grants program regu-
lations early this yesr. On January 10,
1978 (43 FR 1597), fiscal years 1978-81
authorizations were allotted. On June
29, 1978 (43 FR 28202), we pudlisned a
correction of the section number for
the allotment regulation. It is $35.910-
8 in this conformed regulation. On
February 23, 1978 (43 FR 7426), the re-
tmbursement grant regulations (subpt.
D) were revised to extend eligibility
dates. On June 26, 1978 (43 FR 27736),
EPA published final] pretreatment reg-
ulations as 40 CFR part 403, Those
regulations establish the responsibl-
tues of Government, Industry, and the
public to implement national pretreat-
ment standards to control pollutants
that pass through or interfere with
treatment processes In publicly-owned
treatment works or that may contami-
nate sewage sludge.

On August 7, 1978, we published pro-
Posed regulations on public participa-
tion in the Froeran Reaistzr (43 FR
34794), Those regulations implement
section 10l(e) of the FWPCA which
requires EPA to provide for, encour-
age, and assist public participation in
EPA programs. The regulations would
replace 40 CFR part 108 (Public Par-
ticipation In Water Pollution Control)
and 40 CFR part 249 (Public Participa-
tion in Solid Waste Management) with
a new 40 CFR part 25.

References to part 25 are inserted in
this regulation in anticipation of pub-
lication of final public participation
regulations. In the interim any refer-
ence to part 25 in these regulations
should be interpreted as referencing
the current part 105 regulations. The
mew part 25 would establish overall
public participation requirements for
programs under the Clean Water Act,
the Safe Drinking Water Act, and the
Resource Conservation and Recovery
Act, The regulations, tn addition,
revise public participation require-
ments in 40 CFR part 35 subpart E,
specificaily for the construction grants
program, They focus the pubilc’s at-
tention on decisions made during the
planning of the wastewater treatment
facilities. They also provide the oppor-

RULES AND REGULATIONS

tumty for pubilc involvement in later
stages of project development.

EPA published proposed reguiations
for the water quality management
program in the Prpera, RzcisTER on
September 12, 1978 (43 FR 40742).
Those regulations replace 40 CFR
parts 130 and 131 and portions of part
35 with a new 40 CPR part 35, subpart
G, The regulations govern the water
quality management program under
sections 106, 208, and 303(e) of the
FWPCA and include changes made to
(mplement provisions of the 1977 Act.
The regulations require a State/EPA
agreement, which ts intended to serve
as the principal management tool for
the water quailty management pro-
gram, The State/EPA agreement wul
integrate the planning, management,
and implementanion of all water qual-
ity management programs under the
Clean Water Act, RCRA, and SDWA
by fiscal year 1980. At a minimum, the
fiscal year 1979 agreement shall cover
programs authorized dy sections 106,
208(g), 208, 303, and 314 of the Clean
Water Act. The State/EPA agreement
is distinct from the construction grant
delegation agreements that may be ne-
gotiated under section 205(g) of the
FWPCA, a3 amended by the 1977 Act.
The water quality management
(WQM) regulations coordinate the es-
tablishment of State and areawiie
WQM agencies’ sewage treatment pri-
orities with the construction grants
priority system and lists. WQM plans
are to provide certain facility planning
related information such ss planning
area delineations, waste laad alloca-
Uons, and population projection disag-
gregations. Construction grant facility
plans will have to be based on this In-
formation. Overall the WQM program
regulations link that program and the
construction grants program together
much more closely,

On September 20, 1978 (43 FR 42251)
we published in the Peperat RecisTsR
final regulations on State management
assistance grants (subpt. PF). They
make (funds available to States to man-
age the construction grants program
and to hire and train staff needed to
implement delegated functions,

Prom time to time EPA Issues guid-
ance and technical information to sup-
plement regulations and to assist
those participating and interested in
EPA programs. A listing of informa-
tion and copies may be obtained from
the General Services Administration
(8PSS), Centralized Malling Lists Ser-
vices, Building 41, Denver Federal
Center, Denver, Colo, 80225, (See
§35.900(c).)

Discussion of the regulatory changes
being made are grouped by subject
matter. Following the discussion of
each subject area, the preamble identi-
fies those sections in the regulations
related to the subject areas that are

(Let fodvction )

44023

changed. For the technica! amend-
ments each section containing a
change ls discussed separately.

Statz Priority

Sections 20 and 40 of the 1977 Act
modified the policy and procedures ap-
plicable to State project priority plan-
ning and clarified the intent of Con-
gress regarding the roles and responsi-

iiities of the States In preparation of
rity lists. These new provisions of
tae Act require several modifications
to the procedures used by the States
in managing thetr priority lists. Estao-
Uushed priority rating and ranking ¢ri-
teria that are consistent with applica-
ble guidance and these regulations
need not be changed.

The 1977 Act nves the States exclu-
sive authority to rank categertes of
Projects. The categories specified in
the 1977 Act are those usea in the
survey af the cost of needed publicly-
owned treatment works (the needs
survey) and have been defined in
detail in previousiy published guid-
ance for the survey. The reguiations
have been written so that no State is
required to assign a different ranking
to categories of projects, but it may Jo
$0 On an optional basis,

States are expected to continue to
use priority criteria based on the se-
verity of the pollution proolem, the
existing population affected, and
other related factors nec TY tO
meet statutory requirements. All pro-
Jects on the priority lists, including
those benefiting from the setaside pro-
visions, must be rated according to the
priority criteria and subject to the
management procedures contained in
the approved State priority system.
When preparing thelr priority Ust3,
States must take into account the
work completed by designated State
and areawide agencies responsibie for
water quality management.

The legislative history of the 1977
Act indicates that State priority list
planning and management must be
closely Mnked to meeting unfilled
treatment needs before other eligible
treatment works may be funded. The
1977 Act specifically requires, with one
exception, that only projects resulting
in compliance with the enforceable re-
quirements of the Act may he included
on the State's priority list. Projects on.
the State list which do not meet this
requirement are to be removed and al-
ternate projects which do meet the re-
quirements added to use available
funds.

Several commenters on the regula-
tions expressed concern that the sec-
tion on State priorities was very long
compared with the relatively short ref-
erence to priorities in the Clean Water
Act, We belleve that these comments
result from a misunderstanding of the
role of the priority system and priority

FEDERAL REGISTER, VOL 43, NO, 188—WEDNESDAY, SEPTEMBER 27, 1973

-35-


oan
Date of contact: July 2%
Hike Netlasters 1/77 estimate: 857,000
Senior Environmental Quality Spectalist FPA projection: 1,183,000,

Muntetpal Construct lon Grants Section
Department of Health and Welfare
Division of Health and Welfare

State House

Boise, Idaho 83720

(HOR) 94-2633

state projection,
Rodse State Univ: 1,300,009
projection submitted: 77

State Projecttons

Rolse State University has a projection. The Department of Water Resources
has county-wide projections. The Department of Planning, Budget, and
Policy A{fatre has five year projections.

There is a committer of representatives of the Bureav of Policy Planning
and Development, the governor's office, the Department of Water Resources,
the Department of Health and Welfare--Diviston of the Envfronment, EPA,
and personne! from Boise State University, which is trying to establish
a methodology for a uniform set of state ponulation projections for state
planning, but this methodology fs probably several month down the road.

Speckal Activities for EPA

There {5 a water treatment needs survey projection from 1978, to he
revised in 1980. This docsn't include rural areas. It 1s extrapolated
[rom the 1970 Census and the 1977 population estimates. Mc Masters
Indicated that this number fs Little more than 5% too high, though tt

ts not clear to we vhat that means since the number dosen't Include rural
areas. They are stfIt not clear what they are doing about the present
Process; they still do not have a lead agency.

NcHasters indicated that hearings would be hard to get in, maybe not
U1] the f1rst of the year, and they might have to ack EPA for permission
to be late.

The state at the time of our contact was setfonsly behind in complying
with the procera. According té Nc Masters there had heen no effort
until the last three months. And that doesn't seem to have settled
much. But they do have projections for the non-rural areas tn the
needs survey; so they might, with some work, be able to prepare some
acceptable projections. However tt is unlikely that there will be time
for more then # minimal public and local participation. These seem
especially significant because there are areas of the state which have
been showing extremely rapid growth and for which any projections are
likely to be controversial.

ILLINOIS

Pate of contact: August 20

Mitch Reaver, Manager 7/77 estimate: 11,245,000
Planning and Standards Section EPA projection: 12,358,000
Divicton of Water Pollution Control state projection 32,735,000
I Unots FPA projection submitted: 12,735,000

2200 Churchi 11 Road
Springfield, Illinois 62706
(247) 782-3362

State Projections

The Bureau of the Budget has prepared dicaggregations for etght or nine
years with updates in 1973, 1975, 1976, and 1977. 1979 figures are
expected soon. Doing {t this often has been a ttle disruptive. The
goal eventually fs to dlcapgregate every two years. These projecttons
go to the county Level and are the of ficial ones used for al} state
planning. They use a combined demographic/econometric methodology.

Special Activities for EDA

The 1977 disapgregations vere within 3% of EPA, so they are hetng used.
Beaver 1s coordinating the process, though Bureau of the Budget will

Wold the public meeting and probably do the official submission. In

the 208 process they contracted out to the University to do disageregations
to the township Jeve} using combined methodology. The disaggregations
were then taken to the regional planning commissions. The Northeastern
L1linots Planning Commission (the Chicago area) went to most of tts
municipalities; there was more controversy in that area than elsewhere.

Environmental groups were involved through 208 plan involvement; they
are represented on advisory committees.

-111-


3.1 SPECIAL STATE ACTIVITIES FOR THE PROCESS

Of the fifty states, approximately twenty have sufficiently
refined, consistent, and updated processes of preparing and
using projections that little new was needed to comply with
EPA requirements for the October 1 submission except possibly
for the public meeting:

Hawaii, for example, developed a complete set of projections
which were released in March, 1978. Those projections were
automatically used in water quality planning.

Arizona developed a complete set of projections which were
adopted in 1977. A state Executive Order requires these
projections, down to the association-of-governments, or
regional, level, to be used in all state planning. Ail buc
one of Che designated 208 agencies had projections for their
areas no greater than the state-prepared ceilings. The one
whose projections exceeded the state disaggregation is now
revising its projection downward.

Maryland has preexisting projections prepared by their
Department of Planning and used for county water and sewer
plans, They are submitting these figures, meeting the public
meeting requirement in the 208 hearings going on this summer,

The characteristics of states in this category seem to be:

1) having prepared population projections for the state
in the recent past or good enough to still be useful and

2) having prepared projections for subdstate regions which
were used in water quality planning or having already compared
the state's own disaggregations with the projections of designated
208 agencies and begun to reconcile them.

For those states which have had to perform new tasks in
compliance with the EPA guidelines, the tasks included:

a) Preparing a state projection which did not already
exist or deciding to use the EPA projection. West Virginia,
for example, had no preexisting projection. They decided to
use EPA's projection for the state, prepared disaggregations
to the county level, and will hold a public meeting.

-43-


(Ohio, continued)

We've held public hearings on the county level and
small area projections: fourteen hearings in July and
August. Then we'll go back and work one by one with
the communities that don't like their projections....
When we make a change, we go back to the local advisory
committee to get their approval again since it involves
changes for the whole region."

It's time consuming, especially of staff time, but it's
worth it. People may not like what we come up with,
but they are generally agreed to accept it until the
1980 census.

Texas is another state that seems to have achieved considerable
cooperation and interaction between the state and local
governments:

"It was good that the federal government left intrastate
disaggregacions to the state, and the state left this

to smaller units. Noone felt anybody was forcing anything
on anyone. Each county did their own disaggregation, and
with one exception they've all been reconciled,

"There's been discussion, but not much controversy. There
weren't many discrepancies because the local areas had
been working with the governor's office for years on
projections. There were discrepancies in a few local
areas, but there were handled within the counties."

Maryland is a state with considerable experience in projections
and it wants to move towards more interaction:

"In the future we anticipate a more open and cooperative

method for all planning areas -- an advisory group of
state agencies and counties, lots of chance for local
input."

Unfortunately, not all states were equally successful in
achieving local involvement. Some states told us:

"No local government involvement until now."

"Local governments have been involved only by having
received the notice. They won't be involved much until
the facilities planning process (201)."

"T used to consult with local governments and the public
but their information usually isn't good. I don't do
that any more. I do better projections by myself."


RULES AND REGULATIONS

from the Department of Commerce
State projections and their disaggrega-
Uons to designated 208 areawide plan-
ming areas, where the State or desig-
nated 208 agency has already prepared
projections. The final guidelines
permit use of State projections al-
ready prepared by the State Wf the
year 2000 State projection does not
exceed that of the Department of
Commerce projection by more than 5
percent. The Admunistrator may ap-
prove State population projections
that exceed the Department of Com-
merce projections by more than 5 per-
cent if justified by the State. Where a
designated 208 agency has already pre-
pared a population projection for its
area, It may be used if the year 2000
population does not exceed that of the
disaggregation, based on the Depart-
ment of Commerce projection, by
more than 10 percent.

One State suggested allowing a State
prepared population forecast to
exceed the Bureau of Economic Analy-
sis forecast by 10 percent without jus-
tiffcation. The Agency does not concur
because the present 5-percent depar-
ture {s sudstantial. Also, since the
State may increase its total after the
208 agencies have received their var-
lances up to 10 percent, the total final
State departure from the Bureau of
Economic Analysis projection may al-
ready approach 19 percent or even
more in some cases. Another State
commented that States already having
policies of disaggregating State totals
among counties, even within designat-
ed 208 areas, should be allowed to con-
tinue to do so, The Agency agrees and
has included such a provision in the
final guidelines.

One commenter has suggested that
population projections in 201 and 208
plans should no longer be wedded to
existing zoning ordinances, which may
de exclusionary and forbid immigra-
tion by lower income people. Instead
he suggested that fucure population
and the resulting reserve capacity for
grant funded projects should rely on
regional population projections and, in
particular, regional allocations of low-
and moderate-income apartment units.
The Agency cannot fully comply with
this suggestion because it belleves that
zoning and land-use decisions should
be left primaruy with local govern-
mental units, and decisions on cost-ef-
fectiveness should be based on total
and not partial population projections
in an area. However, these regulations
require the local population projec-
tions for 201 plans to fall within ceil-
ings based on disaggregation of State
and regional population totals.

Several commenters advocate 4
much more flexible population fore.
casting approach by permitting use of
population projections other than the

| Bureau of Economic Analysis. The

Agency does not concur because use af
various projections would be inequita-
ble and would lead tn many instances
to funding excessive reserve capacity
to accommodate growth.

One commenter stated that the pop-
ulation disaggregation approach is too
simplistic for interstate metropolitan
areas where factors influencing popu-
lation change go beyond State bound-
aries. The Agency concedes that such
situations may pose difficult forecast.
ing and disaggregation problems. Nev- |
ertheless, the Agency believes the in- )
terstate disaggregation problems can
be worked out through consultations
among the concerned States, designat-
ed 208 agencies and other regional!
planning agencies. H

Some commenters pointed out the |
need for public invoivement int the |
review of the State population disag: |

|

gregations. The Agency agrees that
the public should have an opportumt:
to review and comment on the disag-

gregation before Agency review. Ac: |
cordingly, the final guidelines now re- |
quire the State to noid a public mees- |
ing on its disaggregations before sub- |
mitting them for Agency review.

The Agency believes that the same
population projections should be used |
for both air and water quality plan-/
ning. Appendix A now requires, as an!
initial step toward implementing this
objective, that States, when disaggre-
gating total State population, consult
with organizations of locai officials re-
sponsible for water quality and air
quality planning. In many instances
the organizations certified by Gover-
nors pursuant to section 174(a) of the
Clean Air Act to do air quality plan-
ming are also 208 agencies.

FEDERAL REGISTER, VOL 43,

Some commenters nave objected to
the per capita flow limitations of 60-80
gallons per capita per day (the second
method of estimating wastewater
flows) as being unrealistically low. The
Agency believes that such dry weather
base flow allowances are adequate for
smaller communities where flow data
are lacking. These allowances exclude
infiltration and inflow. Residential
wastewater flows nationwide average
only 45 gallons per capita per day.
Other commenters favor increasing
future per capita flows over time.
They contend that increasing per
capita flows have been observed
during the past 10 years and that with
increasing affluence this trend will
continue. The Agency agrees that per
capita water usage and wastewater
flows have increased in the past but
believes that this trend is reversing.
This can be attmbuted to the increase
of personal water conservation nabits
encouraged by periodic water short
ages or higher water suppiy and sewer-
age costs even in normally water rich
areas. Moreover, plumbing codes,
State laws and ordinances are rapidly

-38-

44033

Deing revised in many areas to require
installation of water-saying fixtures in
new dweilings, hotels, moteis, and
other durldings.

Section 21 of the 1977 Act requires
the Agency, i approving the amount
of reserve capacity for a treatment
works, to tawe into account efforts to
reduce the Mow of sewage ana unnec-
essary water consumption. The Presi-
dent's water resource policy feacures
water conservation as its cornerstone
and requires Federal agencies to
plement appropriate conservation
measures.

The guidelines require a cost-effec-
tiveness evaluation of fMow-reduct.on
measures such as plastic toilet d:
and iow flow showerheads: ct
laws, ordinances, or plumbing coaes -
quiring instailation of water-savin
vices in future habitations, and w:
pricing changes. The grantee must de-
velop a recommended Mow reduction
Program featuring a pubiic .nforma-
tuon program pilus cost-effective meas-
ures {or which the grantee has umple-
mentation authority or can obtain co-
operation from an entity wita such au-
thority. Exempted from these require-
ments are those communities with a
population less than 10,000 or with
average daily base flows, exciuding in-
filtration/inflow and industrial flows.
for treatment works design of less
than 70 g: ms per capita per day or
with ongoing flow reduction programs.

Several commenters have susgesies
that smail commuri! should be en-
couraged to conserve water and thus
should not be exempt from the flaw
reduction requirements, The Agency
concedes that some water conservation
potential exists for smaller commiucsi-
though such communities
use and waste iess Waler than
the larger, more affluent cities. Never-
theless, the Agency believes that the
limited cost savings ovtainabie in
small communities from flow reduc-
tion programs may not be commesiu-
Tate with the admunistrative burden
imposed. Some commenters have
pointed out that the 70 gallons per
capita per day exemption criterion is
too stringent and have suggested a i90
gallons per capita per day criterion.
The Agency disagrees hecause the 70
gallons per capita per day figure,
which represents an average ‘iry
weather base flow, is large enough
exempt most small communities an
water-conserving larger cities, Almos:
all communities, inciuding lar;
water users, would be exempt if
suggested 100 gallons per capita per
day criterion were used.

Two commenters objected to the
flow reduction requirements as being
unreasonable for areas with adequate
water supplies. The Agency disagrees.
During the past 20 years, persistent
drought and accompanying water

Yeh

&

NO. 183—WEDNESDAY, SEPTEMBER 27, 1971


Some states claimed to have discussed projections with their
208 advisory committees. In at least one state, though,
the topic never came up.

One projections agency described its work as "intentionally
a bit ivory-towerish. Environmentalists are not involved."

In some states citizens were actively involved in debates

over popuiation projections at the designated 208 level -
examples are the Atlanta Regional Commission, Southeast
Michigan Council of Governments, Association of (San Francisco)
Bay Area Governments. However our telephone survey was of
state governments and we did not ask about involvement at

this level.

We believe it is fair to say that except for a handful of
states in which the projections are reflective of or used
as growth pzlicy, or those states in which all the decisions
were made at the designated 208 level, there has been
virtually no involvement of the non-governmental public in
the process of deciding how projections should be prepared
or considering the process as it developed.

eT



ANDINA
Date of contacts August 13
Jeff Feller 1/77 eatimate: 5,330,000
Water Foltut fon Control Diviston FFA project fo 5,792,090
State Board of Heal th state projection ¢
1390 W, Michigan Street Projection submitted: same

Indianapolis, Indiana 46206
V7) 633-0735

State Projections

The State Planning and Services Agency had heen Involved with projections
fat one time. Indiana University has prepared projections to the connty
level based on demographic methods and in the Iate fall may he carrying
these to the township level.

Special Activities for ERA

The Board of Health has adopted and used the University county projections.
They applied least squares tegressions to carry them to municipalities,
and the expected Ind{ana University tomship level projections will give
them 9 more secure base for doing this. Tor carrying projectfons dow to
lower levels there fe a contract with Hotcum Tustitute.

The state projection in 5.7% greater than FNA's, and so fn June they
officially requested a variance, as well as isauing notification of a
public meeting September 5. They took the mmbers to public policy
advisory committees for each region. They received some verbal criticisms
but no written cooments. They also met with people in each region.

Other Comments

Recause the Board of Health handles this process, they need nimbers
that are good for health uses too. Rut the Wighway Commission and
Department of Natural Resources probably wn't wse these projections
because they have their own.

If the variance ts accepted, they should have no trouble meeting the
deadline.

Towa

Date of contact: Aupust J

Joe Lynch, Mead 7/77 estimate: 2,879,000
Water Quality Planning Sect ton EPA projection: 3,101,000
Chemicals and Water Quality Division state projection: 3,188,797
Department of Environmental Quality projection submitted: 7
Menry A. Wallace Building

900 E. Grand

Des Moines, Towa 50319
(515) 281-8957

State Projections

The State Office df Planning and Program (OPP), which 1s exsentially
an arm of the governor's office, has done other projections jn the past.

Spectal Activities for EPA

Of took a long time preporing the projections for this process; Lynch
wasn't sure why. In mid-July the Department of Environmental Quality

got the disangregations to county and SMSA, which they sent to the

tegional planning agenctes and asked them to disaggregate and return by
the middle or end of August. The agencies had not previously been informed
that they vould have this task.

Lynch hoped that the dlsapgregations vould he ready for a public meeting
of the Water Quality Commission in September. He doubted that they vould
make the deadline, but they would come close.

-112-

Des Moines, the only 208, has a greater projection than OFP's, and thoy
may want another 10 or 15 thousand over the OPP projection of 390,000.
One other SHSA was also unhappy with its number, and it was not clear
vhat they would do.

No other state agencies are Involved. The facility planning area projec-
tions won't be used for any other purposes, but he presimes the OPP
numbers will be. le didn't know of any public partictpation so far.
There has been no Jocal government favolvement tiIT now.

Other Comments

Lyncy indicated that he had only been tn his present Job for three months,
and that Dennis Vaughn, a staff worker under him, would be more know-
Jedgable (same address, (S15) 281-8953).


208 Plan/ 208 Agency/ 208's/ 208 Level

Section 208 of the Clean Water Act requires states to develop
plans to meet clean water stanJards., Sources of water pollution
come from point sources and non-point sources. Examples of the
latter are agricultural runoff and runoff from urban construction
sites.

The péans, whether for entire states or parts of them, are called
208 plans.

The Governor of a state may choose - or designate - ceztain
substate agencies to prepare the water quality plans for their
geographical areas, Those agencies are called 208 agencies or
208's. Their geographical area is sometimes called the 208 level.

Although these designated 208 agencies in some cases are counties,
more often they are multi-county planning agencies, which in
different states have different legal statuses, sources of funding,
roles, and responsibilities. They are known as:

councils of government (COG's)

areawide planning agencies

metropolitan planning agencies or organizations
associations of government

area planning and development commissions (APDC's)

Oe OOH

However not all agencies with the above names have been
designated for 208 planning!

Needs Survey

EPA conducts Needs Surveys every two years to determine what
is still needed in each state to comply with various portions
of the Clean Water Act. The cost of complying is also
estimated. Population projections are, of course, used in
determining and estimating the needs.

Surveys were conducted in 1973, 1974, 1976, and 1978,

Step 1 Grants

Under the Construction Grants Program (see above), EPA makes
grants in three steps for the construction of a sewage treatment
facility. Step 1, the first, is a planning grant. Step 2 is
for design of the facility and step 3 is for actual construction.
The EPA projections guidelines refer to a deadline after which
all Step 1 grants must use projections consistent with the
guidelines,

-135-


In several states, the person we identified as probably the

one responsible for implementing the guidelines knew little

or nothing about them. In some cases this might have been
because that person supervised someone who knew the process
well; however in other cases there appeared to be no one in

the state who was well acquainted with what the guidelines said.

Several states themselves identified problems with implementing
the guidelines as related to the lack cf clarity within state
government over who was resnonsible. In those states where

the projections agency had refused to participate, an environ-
mental agency sometimes was left holding the ball despite its
feeling it did not have the expertise to do a good job. In
one state three agencies already had projections; one of the
two didn't want the responsibility in this case but the other
two both did. In one state, as of the date of our contact

the Governor had not yet designated a lead agency.

Several states commented that the agency signing the work
agreement with EPA was not the agency with responsibility for
producing the projections. It was therefore difficult to
hold the latter to requirements or deadlines. Furthermore,
since the projections agency is not usually the one which
deals with EPA, there are not good working relationships,
messages can get garbled, and the point of the guidelines can
easily be missed.

In one state an Executive Order prohibits state agencies
from using any projections but those currently being prepared
by a particular agency, but allow others to use preexisting
projections in the interim. The agency trying to comply with
EPA does not know to what degree it can amend its existing
basin plan projections.

Despite all this, all the states appear to be producing some
set of projections and disaggregations for EPA. But the
confusion in some has the effect of slowing down the process,
making it probably less useful to the state, and making public
involvement all but impossible.



A.1 GENERAL SUPPORTIVE COMMENTS

It's good to force states to look at projections because
it makes them think about the impact of the growth, It
will stop local governments from manipulating projections
high or low to get what they want.

Despite the fact that we are participating reluctantly, I
think the process provided good liaison opportunities with
substate agencies.

This makes good sense if done at the beginning of 208 planning
and it will make good sense in 1985 when the new census data
are available.

We're proud of what we've done. Local communities realized
that this will determine the size of their facilities and so
they took it seriously.

This is definitely needed in order to avoid over- and under-
design. It is particularly important for the 208's but not

in rural areas and the SMSA's which are (in that state) mostly
quite small and not showing much growth.

We're already using the interim figures. We're being fairly
stringent About them. We're telling local governments that
consultants will no longer be preparing projections. We'll be
handing the projections to them.

Disaggregating to facility planning areas is a good thing. I've
seena° int of abuse (this person said). A jurisdiction would come
and project the bulk of the growth in one end of the county, and
then a couple of years later they'd come back and project all
their growth in the other end.

No doubt about it. We need standardized population projections
that are acceptable to everyone involved.

I now know more after going through this process.

States should develop their own disaggregations, resolving their

own needs and what EPA will accept. Many states are like us and

haven't had the foresight or resources to develop disaggregations
previously.

The process wasn't very tedious or complicated. For one thing
because we've been here before.

-95-


1.2 HISTORY OF THE EPA PROJECTIONS GUIDELINES

The Federal Water Pollution Control Act Amendments of
1972 stated that the size of any sewage treatment facility
built under the terms of the Act should

“relate directly to the needs to be served by such
works, including sufficient reserve capacity. The
amount of reserve capacity provided shall be approved
by the Administrator (of EPA) on the basis of a
comparison of the cost of constructing such reserves

as a part of the works to be funded and the anticipated
cost of providing expanded capacity at a date when

such capacity will be required." (section 204(a)(5) )

The Act also required EPA to publish cost-effectiveness
guidelines for conducting such an analysis, and to revise
them at least on an annual basis. Guidelines were published,
and a proposed set of amendments to those, incorporating
many of the concepts currently being impiemented, was
circulated in mid-1976. Proposed amendments were then
published in the Federal Register on February 4, 1977.

In 1977, Congress debated and passed amendments to

the Act, now called the Clean Water Act. The House of
Representatives proposed no change in section 204(a)(5).

The Senate, however, proposed that federal funding be

limited to facilities with reserve capacity for ten years

in the future; interceptor sewers and "associated appurtenances"
were to be funded 20 years into the future.

The Senate report stated that, "One purpose of this amendment
is to concentrate available funds on correction of existing
municipal problems" (emphasis added). Senator Muskie
commented that the goal of the funds provided by the Clean
Water Act "is not to finance the future growth needs of the
United States." An Administration representative supported
the Senate proposal, known as the 10-20 formula, citing

the successful California experience in implementing such
limitations and acknowledged that "Overbuilding has been a
problem."



TABLE OF CONTENTS

Cover Letter page 1
Chapter 1: INTRODUCTION 3
1.1 Sierra Club Involvement in Population Projections
1.2 History of the EPA Projections Guidelines
1.3. Objectives of the EPA Guidelines
1.4 Project Procedures
Chapter 2: THE EPA GUIDELINES ON THE USE OF POPULATION PROJECTIONS 15
2.0 Flow Chart for the EPA Projections Guidelines
2.1 A Two-Minute Version of the Guidelines
2.2 A Ten-Minute Version of the Guidelines
2.3 Further Questions
2.4 Examples
2.5 Text of the Guidelines and Discussion in the Federal Register
Chapter 3: SUMMARIES AND CONCLUSIONS: LEAD AGENCIES & EPA 41
3.1 Special State Activities for the Process
3.2 General Attitudes
3.3. Use of Available Time
3.4 Locus of Responsibility Within the States
3.5. Methodologies and Approaches
3.6 Consistency of Projections Within the States
3.7 State Reactions to the EPA Projections
3,8 Variance Requests
3.9 Communications Preblems
3.10 Energy-Impact States
3,11 Timing of the Requirements
3.12 Vision
Chapter 4: SUMMARIES AND CONCLUSIONS: INVOLVEMENT WITHIN THE STATE 65
4.1 Coordination Among State Agencies
4.2 Involvement of Substate Governments
4,3 Public Involvement
4.4 What Remains to be Done

(continued)


This result of our survey may perhaps be surprising, since there
may be an impression in some quarters that states are having
great difficulty with these guidelines. It is certainly
possible that the people with whom we spoke were not being
totally honest with us or were in fact not the ones with the
strong negative opinions. We regard this as unlikely, though,
given the frankness with which they answered many of our
questions and the fact that we spoke with many dozens of

people.

Two states which had opposed the general structure when the

draft guidelines were open for public comment did not do so

in our conversations with them, It should be noted that

the state projections in both those cases were within 5% of

the EPA projection. We do not speculate on how those states
might have reacted had there been significant differences in
these numbers.

Most of the problems mentioned with the guidelines were over
the BEA model, specific state projections, the process of
consultation with the states over those projections, the
timing of these requirements, and the amount of flexibility”
available, or were based on misinterpretations of the
guidelines, These problems are discussed in later sections
of this report.

On the basis of our telephone discussions we suspect that as
states become clearer in understanding the guidelines and as
the relevant state agencies gain experience with projections,
this process will come to work well in most states, including
those which had trouble with it this time.

Appendix A contains 4a selection of supportive and critical
comments made by state representatives on the entire process.

-46-


Se
a

CHAPTER 3

RECOMMENDATIONS

5.1 State Activities to Involve the Public

5.2 Public Meetings on Protections

5,3 Communications Between EPA and the States

5.4 Written Guidance for the States

5.5 States Which Have Had Difficulties

5.6 Involvement of Other State Agencies

5.7 Revisions of the Projections and Integration “ith Other
Federal Requirements

5.8 Earlier Deadline for Variance Requests

5.9 Urban Areas With Decreasing Populations or Low Growth Rates

5.10 Proposed Federal-Wide Process

~79-


$.10 PROPOSED FEDERAL-WIDE PROCESS

The EPA projections guidelines are in many ways a pilot
study for how such a process might operate at a federal-
wide level. As we mentioned in the cover letter to this
report, a proposal for development of consistent projections
which must be used in those federal programs which use
projections in a funding formula is expected to be proposed
by OMB & the Department of Commerce this fall.

Much of the analysis and many of the recommendations in this report will,
we hope, te of use to those developing this proposal,

We offer the following specific recommendations:

A. Most states would find federal-wide consistency a substantial
step forward, Several complained to us that different
requirements in EPA, HUD, DOT, and HEW programs cause them
to need to produce several sets of projections.

B. Although most states were satisfied with the EPA numbers,
this was because of their similarity to the states’ own
projections and the provision in the guidelines allowing
them to use the latter if differences were minor. In order
to maintain smooth working relationships with states, to
increase the possibility of this process being useful to
the states in their own, non-federally-required work,
and to avoid duplication of efforts by states, we feel
strongly that variances such as the 5% one allowed by EPA
should be maintained.

C. Our recommendation for written guidance to the states (see
section 5.4) is even more important if the projections are
to be used more widely. This guidance should not simply
be a rephrasing of guidelines, but should include examples,
and answers to common questions in easily readable format.
We believe the materials should be written at a level
understandable to the potentially-interested public.

-89-


cl

United States Washington DC 20460 September 1979
Environmental Protection
Agency 100R79101

SEPA A Progress Report:

State Implementation

° | of EPA Guidleines
on the Use of Population

hdd.

bn

EPA
100/
1980.2


(tassachuset ts)

eo booklet
be ued by

Alter the process 4s completed, the state Isp)
giving al? the agreed-upon projections,
all state, regional, and local governments in

Other Conments

Massachusetts Le to be conmended for its comprehensive prowth policy process
and the extent of citfven and local government participation.

ince the state's Office of State Planning ls ao longer In existence,
estate will find m vay to continue ite process of preparing state
projections.

MLanicAN

Date of contact +
Ron Wilson T/T7T estimate: 9,129,000
Gilef of Water Quality Management EVA project fon: 000
Planning Section state's projection: 000

Department of Natural Resources Projection submitted: 10,504,000

517/374-9437

Larry Rosen
Office of the Budget

Dept. of Management and the Budget
lewis Cass Building

F.0, Box 300:
Lansing, Mich.
517/373-7930

49909

State Projections

The Department of Hanagement and the Budget (NMI) released a set of comty
level projections March, 1978, prepared using a demographic model.

‘The DNB figures are 1.85% over EPA's and will presumably be submitted without
change. The entire state is covered by 14 designated areas, each of which did
a disaggregation in preparing their water quality management plan. ALL but
three are within the DMB figures, and those three are revising as » condition
of EPA's 208 plan approval.

Public participation had not yet been worked out, but vould probably he done
by PNR. Wilson indicated that there vas a chance that public participation
might delay the state beyond the October 1 deadIine.

Other Comments

There is a good chance that these projections will be used by all state
Programs; they at least must be satisfactory for the whole INR

It is our understanding that the person most centrally involved in the process
in Michigan is David Milstein, at the same address and phone as Rosen, who was
on vacation at the time of our survey.

It sods lke the public participation, whether or not completed in time for
the October 1 deadline, in being done more or less as an afterthought.

-116-


1s it fair for a community
that consciously ur unconsciously
‘ submits an inflated projection
to receive a bigger chunk of the tax dollars?

sewers—allempt to solve current problems (such as water poilu-
tion), or may provide for additional capacity to continue (0 abate
a problem of to anticipate a future problem. A new reservoir
may, lor example, provide for the anticipated water needs of a
communtty that does not now have a water shortage.

In order to determine these future needs, the agency propos:
Ing a proyect prepares a projection of the quantities involved,
whether they're quantities of water, untreated sewage or vehi-
cles expected. In gach cuse, an essential component of the de-
mand projection iy a projection of the aumber of people who will
be living in the area im question or who will b¢ served by the
tacnity, The population projection ty then used to determine
whether a project is needed, where i should be located, how
large it should be, the cost-eftectiveness of the proposal and,
finally, the amount of money to be made available by the appro-
pmate level of government. Population projections, therefore,
are crucial and indispensable factors in the evaluation of needs
by communities and by government agencies with funding
authority.

Population projections are also used in devising computer
models that involve both population and egonomic projections,
‘These models are uscd to estimate the effectiveness of proposed
environmental controls. For example, a model may postulate
various types of air pollutants emitted by different sources, fac-
toc in topography und weather conditions, then evaluate various
strategies for meeting federal atr-quality standards. Modeling
cun also be used to gauge the effect on populauon of proposed
energy development, a new industrial facility or water devel-
opment. But population projections are much more than a rather
academic, statistical exercise, The projections themselves cun
have a tremendous effect on growth. This is because construc:
ion projects olten foster the populauon and economic changes
that were projected. In other words, if a community provides
yewer hookups for a doubled population, peopic may move to
that community —because there are sewer hookups.

This situation poses certuin problems:

Ly it fair for a community that consciously or unconsciously
submits an inflated projection to receive a bigger chunk of the
tax dollars?

© The growth that is induced by an inflated population proyee-
ton may retlect the desires of only certain special interests ina
community.

© One federal program may undermine the goals of another, as
when the federal government funds a sewage treatment plant to
solve current water pollution problems, und the reserve cupacity
of that plant tacilitutes growth in an arva that depends heavily on
the automobile. As a result, auto commuting increases, and air
quality gets worse.

Another example would be if a city with decreasing popula-
tion were forced to use a proyection retlecting only the “current
trends,” thereby atding and accelerating the population de-
crease, This direction might be contrary to an established federal
or state or logal policy of rebuilding the city’s population and
industrial base.

Different government avencies have experienced different
problems connected with population projections. In the
abstract, these problems may seem aimost impossibly abstruse,
but case studies shed some light.

Water Development and a Wilderness Study Area:
The Forest Service and Medicine Bow
National Forest, Wyoming

He U.S. Forest Service, within the Department of Agricul-

ture. has been developing a management plan for the Huston
Park Unit of the Medicine Bow National Forest in Wyoming
The unit is near the city of Cheyenne, and the key point of
contention has been the extent to which the Forest Service wall
accede to the Cheyenne Water Board's request that land be re-
served for further development of the city’s water supplies.
Some of the remaining arcas within the unit were to be made
available for study for potential inciusion in the National Wil.
derness Preservation System. The five options presented ranged
trom reserving one third of the acreaue requested toc potential
water development to reserving all the acreage requested. In
area, the acreage requesicd for wilderness study ranged from
none to 43,010 acres. The orginal choice made by the Forest
Service was to reserve all the acreage requested for water devel-
opment and to allocate 29,770 acres for wilderness study.

Subsiantial controversy arose, however, alter publivation ot
the Draft Environmental Impact Statement in late 1976. The
Cheyenne Water Board hud used a projection of 113,490 for
Cheyenne for the year 2000, compared with 43,313 in 1973
However the Economie Rescarch Unit of the Office of the State
Planning Coordinutor had projected a year-2000 population of
73,400 for the entire Laramie County, ia which Cheyenne is
located, of which about 60,000 would be in the city of
Cheyenne. This discrepancy was noted not only by The Wilder-
ness Society and the Wyoming Outdoor Council, but also by the
Oftice of Industrial Siting Administration of the state and by the
governor. Governor Ed Herschler wrote that, “The draft state-
ment... fails to adequately address several important matters.
. . The discussion of the population projections and the in-
creased demand tor water resulting from the projected popula-
tion should be more specific and definitive.”

Objections were sufficiently compelling that in the final re-
port, dated September 1977, the Forest Service had changed tts
recommended management pian to one allocating about half the
requested acreage for potential water development and 36,840
acres for wilderness study. The city immediately appealed to the
director of the Forest Service, and the matter is still being
negotiated,

Water Development and Hydroelectric Power:
The Army Corps of Engineers in Alaska
TT Army Corps of Engineers has proposed building a dam
on the wild Susitna River in Alaska. [f built, this would be
the most expensive hydroelectric dam project in the Corps’ his-
tory, with costs estimated between $1.5 billion and $6 billion.

SIERRA 35


The fifty states are now in the process of implementing
relatively new EPA guidelines on the use of population
projections in its programs. The attached report is one
of the results of a small grant from the Environmental
Protection Agency to the Sierra Club to conduct a tele-
phone survey of the states and let you know how well

the process has been going. We have paid particular
attention to how much and what kinds of public partici-
pation has been taking place.

Section 4.4 of the report describes opportunities for
your involvement in the next few months,

The EPA process is also important because it may serve
as a model for similar efforts in other federal agencies.
The Office of Management & Budget and Department of
Commerce are expected, this fall, to issue a proposal
for the development and use of a consistent set of popu-
lation projections in all federal programs which use
projections in a funding formula. This is likely to
involve not only EPA's pollution control programs, but
also various transportation, water policy, and urban
development programs (and others) throughout the federal
government.

We are available to assist you in learning more about

EPA's use of population projections and what your state

has been doing. As a result of our telephone conversations,
we have much more information about each state than we

have been able to include in this report. We strongly

urge anyone interested in becoming involved at the state
level to contact us for assistance and additional ideas.

Finally, the Sierra Club publishes Population Report, a
free newsletter that focuses on federal policy on the use

of population projections and national trends in population
growth. We would be happy to send it to you.

Ses tiaiy  Chall Serman

Donald Forman

Thanks to Annie Stine for the graphics and Marina Wadopian
for production assistance.


MINNESOTA
Date of contact: August 16

Douglas Wall 7/77 estimates 3,975,000
Facilities Section EPA projectior 4,505,000,
Mionesota Poldution Control Agency state's projections:

1995 W. Commty Road 8-2 original’ 4,652,800
Roseville, Minn. 55113 revised : 4,529,800
612/296-7241 projection submitted: 6,529,800

State Projections

There is a state demographer in the State Planning Agency who since 3975 has
Prepared projections dow to the county leveJ. Recently some revictons have
been made to this total. It ts well within 5% of EPA. The projections are
based on “current trends and sophisticated modeling”.

vities for EPA

The projections were submitted to EPA a year and a half ago and approved then.
Nall was not avare that any public meeting had heen held; so a meeting ts
Probably necessary befere these nusbers can be resubmitted.

In the one designated area, Mlnnenpolis-Saint Paul, the metro counci} has
developed projections dawn to the tovnship level.

In 1974-76 projections were prepared for cities and townships where a sewage
treatment need was identi fled.

Other Comments.

Assuming that it schedules 9 public meeting promptly, the state should have no
Bteat trouble meting the deadiine, but this is only because it had preexisting
Projections. We spoke to people {n 201 and 208 agencies vho had never heard of
the process, and Nall himself seemed unaware that there vas a public
parthelpation requirement.

MISSISSIPrL

Date of contacts July 25

David Lewis, chtet 7/77 estimate: 2,389,000
Muntc. Facilittes Sect lon EPA projection: 2,740,000
Bureau of follution Control state projection: 7
Department of Natural projection subm{tted: EPA plus 5%

Resources
7.0, Box 827

Robert F. Lee Building
Jackson, Mississipp! 39205
(601) 354-2550

State Frojections

Levis didn't know spectfically vhat other projections exinted in the
state, hut he keeps running into them for Jots of cities and chambers
of commerce. Also, the atate maintains a “cap” projection under which
all planning 19 done, but there are several different disagarepations.

The agency preparing disaggregations is the Research and Development
Center of Mississippl. Last fall the state asked for a 5% variance
and got it. They felt this was a Little lov, but was easier than
applying for a bigger variance. Then they disaggregated to counties
using a combined methodology. They may be having counties disaggregate
themselves Further; we are not clear. No other state agencies are
involved in the process. The projections will be used only for water
quality programs (208) and are already being used. They sent EPA 6
copy, they thought, lost September. The final offictal submission,
with a few minor modifications still under preparation, will be by
October 1, probably around the first of September. The delay ts
because they've just had a reorganization and they want to give the
new commission time to get orfented before they ask it to approve the
projections.

They wil probably schedule public meetings with municipal associations
and the environmental advisory group (Audubon, Sierra Club, etc.).
There's a public meeting scheduled for early September for the overall
state 106 plan (water quality plan for the following year) because
the projections are to be updated yearly. In apring there were public
meetings on 208 plans including projections vhich vere almost the same
as the current ones. They've received no coments on projections.

-117-


WEDNESDAY, SEPTEMBER 27,
1978

PART Ill

ENVIRONMENTAL
PROTECTION
AGENCY

MUNICIPAL
WASTEWATER
TREATMENT WORKS

Construction Grants Program

-33-


A.2 GENERAL NEGATIVE COMMENTS

The requirements are difficult to read.

EPA has said that if there's some reason for deviating from
these projections they'll be flexible but most people (in our
local governments) are afraid that EPA won't allow any change
in the projections. We're afraid they'll put these in concrete.

We're under some awfully rigid requirements that could cause
problems for a specific county, say one where the figures don't
reflect what we (now) know or expect. The tools of the trade
don't allow us to project in a rapidly expanding county.

The EPA should ask states for projections. They'd get more
state input. The regulations seemed not to realize that lots
of people across the country are wrestling or dealing with the
same thing.

They (EPA) made no effort to get input the way the states are
required to get it. The state projection just showed up in
the mail one day. (comment of two states)

The system set up now is workable. But it's probably too hard
to deal with. It's so structured there's no way to deal with
anything out of the ordinary.

The whole thing is a lot of monkey business, an exercise in
futility, an annoyance. It should be done case by case; the
total of the parts might well exceed the whole. If we're looking
at a town that looks like it's going to grow, we give it

funding for growth.

We didn't get enough money for planning in the non-designated
parts of the state and as a result our projections aren't very
good there, We're telling our contractors that the local numbers
shouldn't be treated as gospel for 201 planning.

Doing disaggregations to the county level is worthwhile, but
doing them in rural areas to facility planning areas is not.
The regs. seem tiore appropriate for denser populated urban states.

We shouldn't have to do this as part of the statewide 208 program.
It's nore related to Construction Grants in 205g or someone else.

These guidelines are constructed to produce a "convenient" pro-
jection. But really you should be going to the level of govern-
ment which hes the most information, which is some cases will
be a local government not the state or the feds.

-97-


APPENDICES

-91-


Disclaimers

We attempted to record our conversations with the states and

to summarize them as accurately as possible. Because these

were phone interviews, and because the states did not have

an opportunity to review our summaries, it is possible we have
misrepresented details of the situation in some states. Nonetheless,
we believe that the overall picture we-present in this report is

an accurate one, representing the situation in each of the states

as of the date of our discussions with them and as reported by the
individuals we contacted.

In some cases we found that different individuals in ome state
gave very different accounts of the general process of prepar-
ing projections in the state and how the state was complying
with EPA; therefore it is possible that for some states in
which we spoke with only one person, the picture we received
is not complete.

Furthermore, our conversations were with individuals who at
times were undoubtedly expressing their personal opinions
rather than official views of the states. Our discussion of
suggestions for improving the process and general attitudes
reflects a compilation of these individual views and should
not be interpreted to necessarily reflect the official views
of the states.

In many states the process of complying with EPA guidelines
was nowhere near completed at the time of our discussions
with them. The situation in particular stat<+s, then, may be
different at the time of publication of this report than
when our information was gathered.

Finally, the report includes stories of particular states
and opinions of individuals with whom we spoke. Those
opinions, although sometimes placed in quotation marks,
are in some cases paraphrases. We attempted to retain the
intent of the speaker while clarifying wording and grammar.

-14-


3.8 VARIANCE REQUESTS

Although a few states had great disagreements with the EPA
projections for their area, from a nationwide perspective
there was general satisfaction with chose projections.

According to our telephone interviews, we believe that

three states requested variances of more than 5% by August 15:
Colorado, Indiana, and Nevada. We believe that possibly; six

to elzven additional states are likely to make such requests

by October 1. These include Montana, Utah, Wyoming, Washington,
New Mexico, and Oklahoma, as well as others who have not yet
decided what they will do.

The largest percentage increase we expect to be submitted

will be approximately 35% (Utah), with the largest numerical
increase possibly being almost a million and a half from one
eastern state.

Although controversy over the state aumbers is restricted to
a velatively small mmber of states, the differences can
imply major and potentially serious impacts within those
states.

Several states were unclear about what kind of supporting
information EPA would want to accompany a request for a
variance.

Four states definitely are planning to use the provision
of the guidelines allowing up to 19% variances ‘or de:
208 agencies with preexisting projections: California,
Colorado, Georgia, and New York, Approximately half the
states have decided not to take advantage of that provision;
this includes several states in which designated agencies
have projections larger than those which the state has or
will produce. The remainder of the states either have not
yet compared their numbers with the 208's projections, have
not yet prepared their own disaggregations, or did not
indicate to us what they intended to do.

are2

-38-


-104-


B, Briefing of 208 Advisory Committees

Many states have statewide and/or regional citizens advisory
committees for their water quality programs. In at least one
case we know that such a committee never discussed projections,
and we suspect the situation to be widespread. We urge states to
specifically inform these committees about projections. This

is important even in states that have essentially completed

the projections process, because these committees need to under-
stand the role of projections in order to help integrate them
into the overall continuing planning process for clean water.

i

BI

C. Regularly Inv the Public in Projections

We recommend that states regularly involve the public - the non-
governmental public in particular - in their ongoing work of
developing and using population projections, whether tied to

an environmental planning program or not.

In section 5.10 below we recommend that states establish

formal advisory committees specifically on the issue of population
projections, with mandatory membership of a certain number of
non~governmental individuals with varied backgrounds and interests.

D. Involvement of "Population People" in Environmental Planning

State avencies managing federal or state environmental planning
programs should establish contacts with demographers, population
organizations such as Zero Population Growth, and other individuals
and groups who might be particularly interested in population.

This is especially important in states where projections are
prepared by water agencies who might otherwise lack demographic
expertise and knowledge of who in the state is mterested in
population per se. These people and organizations might be

added to mailing lists on projections-related issues but also,
being few in number in some states, where appropriate might be
contacted personally as well.



volvement in any contract dispute will
not make EPA a party to any contract
entered into by the grantee. (See
§35.938~8.)

(d) Delegation to States. The author-
{ty to provide technical and legal as-
sistance in the administration of con-
tract matters described in this section
may Se delegated to a State agency
under Subpart ¥ of this part if the
State agency can demonstrate that iL
has the appropriate legai authority to
undertake such functions.

| APPENDIX A

COST-EYTECTIVENESS ANALYSIS GUIDELINES

1. Purpose. These guidelines represent
Agency policies and procedures for deter-
mining the most cost-effective vaste treat-
ment Management system or component
part.

2. Authority, These suidelines are pro.
vided under sections 2122C) ana 217 of
the Clean Water Act,

2. Applicadility, These guidelines, except
as otherwise noted, apply to all facilities
planning under step { grant assistance
awarded after September 30, 1978. The
quidetines also apply to Stace or locally f-
hanced facilities planning on which subse-
quent step 2 or step 3 Federal grant assist-
ance is based.

4. Definitions. Terms used in these guide-
lines are defined 2s follows:

a Waste treatment management system
Used synonymously with “complete waste
treatment system” as defined in $35.905 of
this subpart,

b. Cost-effectiveness anclysis. An analysis
performed to determine which waste treat-
ment management system or component
part will result in the minimum total re-
sources costs over time to meet Federal,
State, or local requirements.

¢. Planning period. The period over which
a waste trestment management system 3
evaluated for cost-effectiveness. The plan-
ning period begins with the system's initial
operation.

d. Useful We The estimated period of
ume during which treatment works or a
compenent of a waste treatment manage-
ment system will be operated.

e. Disaggregation. The process or result of
aking down a sum total of population or
economic activity for 2 State or other fur's-
diction (Le., designated 208 area dr SMSA)
into smailer areas or junsdictions.

$. [dentyicetion, selection, and screening
of alternatives, 3. (denti/ication of alterna
(aves. All feasible alternative vaste manage:
ment systems shail be Initlally Identified.
These alternatives should include systems
discharging to receiving waters, land appli-
cation systems, on-site and other non-cen-
tralized systems, including revenue generat-
ing applications, and systems employing the
reuse of wastewater and recycyling of poi-
lutants. In identifying alternatives, the ap-
plicant shail consider the possibility of 10
action and staged development of the
system.

d. Screening of alternatives. The identi.
fied alternatives shail be systematically
screened to determine those capable of
meeting the applicaole Federal, State and
local eriteris.

@. Selection of aiternatives. The identified
alternatives shall be initially analyzed to de-
termine which systems have cost-effective

RULES ANO REGULATIONS

potential and a hich should be fully evaluat-
ad according to the cost-effectiveness analy
sis procedures established in the guidelines.

a. Extent of s/fort The extent of effort
and the level cif sophistication used in the
cost-effectiveness analysis should reflect the
project's size ond importance. Where proc:
esses or techniques are cisimed to be inno-
vative tecnnology on zie basis of the cost
reduction eritzrion contained in paragraph
SeC1) of anperidix Sto this subpart, a suffi-
ciently detailed cost analysis shal! be inciud-
ed to substantiate the claim +o the satisfac
tion of the Regional Administrator.

6. Cost-effecctiveness anacysts procedures.

a. Method of’ analysts, The resources costs
shail be determined by evaluating opportu-
AMty costs. For resources that can be éx-
pressed In monetary terms, the analysis stil
use the Interast (discount) rate established
in paragraph 6e. Monetary costs shall be
calculated in terms of present worth values
or equivalent annual values over the plan-
ning period defined in section 40. The anal-
ysis Shall deserpuvely present aonmorie-
tary factors 1 e.g.. social and environmental)
in order to determine their significance and
impact. Nongaonetary factors nclude prima-
Ty and secondary environmental effects, im-
plementation, capability, operapility, per-
formance reliability and Mexidiitty. AL
though sucn factors as use and recovery of
energy and scarce resources and recycting ot
nutrients are to de inctuaed in the monetary
eost analysis. the non-monetary evaluation
shall also inciude them. The most cost-effec:
tive alternative shail be the waste treatment
management system which the analysis de-
termines to have the lowest present worth
or equivaient annual value uniess nonmone-
tary costs are overriding. The most cost-ef-
fective alternative must also meet the mini
mum requirements of applicable effuent
limitations, groundwater protection, or
other applicable standards estabtished
under the Act.

». Planting penod. The pianning period
for the cosi:-effectiveness analysis shall be
20 years,

c. Elements of monetary costs. The mone-
tary costs to de considered shail include the
total value of the resources which are at-
tributable to the waste treatment manage
ment system or to one of its component
parts. To dete “mine these values, all monies
necessary for capital construction costs and
operation and msintenence costs shail be
identified,

() Capital construction costs used in a
cost-effective analysis shail Inctude all con-
tractors’ costs cf construction including
overhead and profit, costs of land, reloca-
tlon, and right-of-way and easement acquisi-
Uon: costs of desig enyineering, fleld exp
ration anc engineering services during con-
struction: costs of admimustrative and legal
services including costs of bond sales: star-
tup costs such as operator training: ana in-
terest during construction. Capital construc-
ton costs shail also Include contingency
allowances consistent with the cost esti:
mate's level of precision and detail.

(Q) The costeffectiveness analysis shall
include annual costs for operation and
maintanance (including routine replacement
of equipment and equipment parts). These
costs sfiall be adequate to ensure effective
and dependable operation during ine sys-
tem’s planning period. Annual costs shail be
divided between fixed annual costs and costs
which would depend on the annual quanuty
of waste water collected and treated.

44087

Annual revenues generated by the waste
treatment management system through
energy recovery, crop production, or other
outputs shail de deducted from the annual
custs for operation and maintenance .a ac-
cordance witn guldance issued by the Ad-
muustrator.

d. Pres. The applicant shall calculaze the
various components of costs on the dasis of
market prices prevailing at he time of tne
cost-effectiveness analysis.
shall not allow for inflation of wages and
prices, except those ‘or land, as described in
Daragraph Sh(1} and for natural gas, This
stipulation is based on ihe :mipled assump-
tion that prices, other than the exceptions,
for resources involved in treatment works
construction and operation, will tend 20
cnange wer ime approximately the
same percentage. Changes 2 general
lever of prices will not affect the rasuits o¢
the cost-effectiveness analysis. Natural gas
prices shail be escalated 3¢ a comound race
of 4 percent annually over che planing
pertod, unless the Regional Administrator
determines that the grantee has fied
use of a greater or lesser percentage rased
upon regional ditferentials between Aistori-
cal natural gas price escalatisn and ¢on-
struction cost escalation. Land prices shail
be appreciated as provided in paragrapn
Shei). Boch historical data and (ature gr3-
jections support the gas and land price =3ca-
laUons relative to those for other goods and
services related to waste water treatment
Price escalation rates may de updated per
odicaily in accordance witn Agency gus
ines

interest (discount) rate The rate why
the Water Resources Council ssiadisnes an-
auaily for evaluation of water resource pro-
jects shall Se used.

L Interest during construction. (1) Where
capital expenditures can de expected zo be
fairly uniform during the construction
period, interest during construction may be
calculated at {=1/2PCi where:

Tethe interest accrued during the construc.
tion period,

P= the construction period in yea!

Cathe total capital expenditures,

{athe interest rate (discount rate in section
Be).

(2) Where expenditures will not be uni-
form, or when the construction period sill
be greater than 4 years, interest during ¢:
struction shail de calculated on 3 year-by-
year Dasis.

a. Useful te. (1) The treatment works’
useful Ufe for @ cost-effectiveness analysis
shall de as follows

Land—permanert,

Waste water conveyance structures (in.
cludes collection systems, outfall cines,
Interceptors, force mains, tunnels,
ete.)—50 years.

Other structures (includes plant building,
concrete process Lanasze, dasins, lft sta-
tions structures, ete 30-30 years.

Process squipment—15-20 years.

Auxary equipment—19-15 years.

(2) Other useful i.fe periods will de accent-
able when sufficient justification can be
provided. Where a system or a component is
for interim service, the anticipated useful
life shall be reduced to the period for inter.
im service.

hn. Salvage value. (1) Land purchased for
treatment works, including and ised as
part of che treatment process or for ult-
mate disposal of residues, may be assumed

FEDERAL REGISTER, VOL 43, NO. 188—WEDNESDAY, SEPTEMBER 27, 1973

-39-


"Trend" and "Policy" Projections

Although in some cases these two sorts of approaches to

a projection cannot be precisely distinguished, we use the

terms in the following ways: A projection which relies only

on past or current trends in job creation, migration, fertility,
land use, etc. or includes only future events out of the control
of public policy (or decisions already made) is a "trend"

or "baseline" projection, A baSeline projection is sometines
also defined as "a projection based on a defined set of

economic and/or demographic assumptions and which attempt to
capture and reflect the essence of historical growrh patterns.
They do not attempt to take into account changes in intervention
strategies by any level of government or by the private sector.”
This perhaps does not clear up the definition, since we are

not here defining"intervention strategy"!

We are using "policy" projection to refer to situations
where a state government has articulated goals for the amount
or distribution of growth in the state. In some cases these
involve protection of agricultural land, prevention of sprawl,
revitalization of cities, or others. These policies may be
being implemented in other state programs or the state may be
using the EPA process, and its effect on directing federal
money within the state, as a or the tool to implement the
state's goals.

=52-


PENNSYLVANIA

Date of contact: August 6

Ken Rartal 7/77 estimate: 11,785,000
Department of Environmental Resources (DER) FPA projection: 32,165,000
Fulton Building state's 1973

7.0, Box 2063 projection: LA + 11.9%
Marcisburg, Pennsylvania 17170 atate's 1977 conghatent with
(717) 787-3481 projection: thy

projection submitted: 77

State Projections

The Office of State Planning and Nevelopment (OSFD) in the governor's
office has general recpenstbilities for developing projections. Their

1973 projections used the same methodology as REA and the National Planning
Assoctatton, and have heen used in their comprehensive planning. As a
result of comprehensive water quality planning, the 1973 numbers were
Sisagarenated virtually to Facility planning areas. The strateny for the
1973 county and local projections war to begin with OSPD county projections.
‘Then the state negotiated with regtonal and county planning commissions,
who played a major role in local projections. It took almost two years.

The 1977 projectSons use fundamentally the same methods as BEA, but pe
only to the county level. OSPD's figures are not mandatorily used, but
some agencies douse them. DER tries to use consistent projections for
water quality and quantity, air quality, solld waste, etc. -- as far as
allowed.

Spectal Activities for ELA

There was a perfod of floundering because of confusion over the regula-
tions. It 1s not yet clear which set of OSTD projections will he avbmitted,
because ff they use the more recent ones, they vill then have to prepare
new disangrepations to (acklity planning areas, and it fe felt that thts
is too big a task. The decisfon as to which set will he used will not
Include public input, but the state wil} provide the basis for the decision
to the public eo that ft wil) be open to after the fact comment. Either
way, county and local governments are expected to object that their pro-
Jections are too low.

Using the 1973 projections vould require 9 variance request. Thefr
principal procedure for public participation will be to issue a public
notice in the Pennsylvania Bulletin (the state equivalent to the

for certification by the governor, a set of projections, It would
Indicate that no public hearing or meeting 1s planned unless public comment
Indicates the need. There war extensive public involvement in the 197)
projections, If they should go to the 1977 projections, they would probably

hold 9 meeting.

(Pennsylvania)

They had not thought about vays of Javolving citizens, environmental groups,
or population prople. The only area where they've had response is the
Philadelphia area, where many responses are on population. Many are from
local governments saying, “our figure ts too Low".

Other Comments:

We are in contact with an activist who reports having contacted in February
People in both DER and OSPD and being mable Co find anyone working wth the
Process at the state level. DER said that everything was being done at the
regional level. We are concemed that this sort of misJeading state response
to chtizen inquiries could have a damping effect on puble particlpation.

The state has had considerable difficulty due to confusions aver what vas
required by the reguiations. It appears that this has been solved, and the
State will meet the October 1 deadline, unless it requests a variance and
the request is rejected.

-125-



BEA's Model

Some states use or prefer demographic to econometric models
(see Glossary). Since BEA used the latter, it was difficult
for those states to compare their own projections with EPA's
and evaluate the differences

One state did not like any federal agency coming up with
mumbers for the states at all, but added that ZPA is "taking
the heat’ only because they instituted this process first.
(It should be noted here that we did not find as much heat
as several states thought we would)

"BEA didn't take into account energy development: uranium,
coal, oil, and gas.”

One state complained that several of BEA's assumptions are
unrealistic in general and particularly bad for that state:
* 42 unemp loyuent
* no cyclic fluctuacions in the economy
* people moving primarily in resronse to jobs and income,
rather than "quality of life" considerations."

Trend Projections

Two states in the northeast objected to EPA having used
“current trends" in preparing projections for the states.
This, they said, was inconsistent with the President's Urban
Policy, particularly if funding is in any way tied to the
numbers. They felt that federal policies should be used to
prepare projections, giving more weight to already-developed
communities in the northeast.

Estimates

3 states disagreed with the estimates of past and present
population used by BEA as inputs for projecting as being
incompatible with the state’s own assumptions and with those
used in other programs. One me:tioned specifically BEA's
state-by-state allocation of the 1970 census undercount;

this factor is not accounted for in the state's own projections
mor, they said, in Bureau of the Census estimates. As a
result, one state commented, EPA ensured that the projections
developed in compliance with EPA requirements will not be

used for any other purposes within the state.

“another state mentioned that the BEA estimates and projections
do not include the military population or ship's crews, while

the state's own do. However in this case the state's projections
is still less than BEA's; since the state uses its own fore-
casts in planning, it really doesn't matter.

a third state mentioned that the undercount of illegal aliens
is significant in that state and needs to be dealt with.

-57-


States whose projections reflect policies

Hawaii has an ongoing State Commission on Population and Hawaii's
Future, composed of seven public members, a representative of
state government, and one from the U.S. Department of Defense.
The Commission is very involved in the development of the
projections, and the latter reflect a number of growth policy
considerations involving distribution of population among the
islands and the overall economic assumptions used in preparing
the state projection.

Connecticut's upcoming set of projections will reflect a Stace
ian of Conservation and Development approved by the legislature.

New Jersey's projections are being specifically designed to
reflect certain goals of the administration: preservation and
enhancement of existing urban areas, substantial reduction in
growth in currently undeveloped areas, and maintenance of moderate
rates of growth in suburbs. These projections will be presented
to 208 advisory committees and others for their response.

California's projections reflect the zdministration’s commitment
to an urban strategy, one of whore components is having state
agencies use projections which have been prepared by councils
of government.

1

Massachusett: projections were initially developed by a

state agency but were the subject of extensive discussions
throughout the state as part of the Massachusetts Growth Policy
Report. Local Growth Policy Committees existed in 330 of the
state's 351 communities and meetings and discussions were held
over a 20 month period. The question of how and where
Massachusetts’ communities should change was widely debated and
projections were adjusted to form a mutually consistent and
acceptable set which will now be used in ali state and local
planning.



5.3 COMMUNICATIONS BETWEEN EPA AND THE STATES

(see sections 3.3 & 3.9)

Various problems of communication between EPA and the
states were common, and described in detail in sections 3.3
and 3.9, EPA should be careful to highlight those portions
of regulations which require something new of the states,
particularly (as in this case) when a process is likely to
involve extentive negotiations with substate agencies.

Such discussions should occur well before any deadlines in
order to make it possible for states to finish on time.

5.4 WRITTEN GUIDANCE FOR THE STATES

(see chapters 3 & 4)

EPA should produce written, explanatory materials for the
states on what is being asked of them, why the guidelines were
developed, and how they can be implemented in various ways.

Availability of such material would , we hope, eliminate many
of the misunderstandings which occurred this time around and
also provide states with more of an understanding of EPA's
reasons for promulgating these guidelines. Otherwise, states
often regard them simply as another bureaucratic requirement.
It should be remember that in many states the agencies pro-
ducing the projections have no direct contact with EPA or
familiarity with the impact of use of the projections in
various programs.

Furthermore, most states did not avail chemseives of the
opportunities made possible by the flexibility written into
the guidelines. In many cases their staff was overworked and
unlikely to notice anything but the mere requirements of

the guidelines; in other cases states or the programs respon-
sible were sufficiently unfamiliar with the use of population
projections, that other possibilities did not occur to them.

Guidance from EPA might well include case studies and examples
of how the guidelines might be applied in various circumstances.

-85-


The process will probably result in benefits, particularly if
people work out good compromises.

We try hard to keep projects from getting out of hand.

Consistent projections (which we've had in the state) have
been a good experience.

I concur in EPA's approach of getting everybody involved.

EPA should extent this approach to its other programs, NPDES
permits and non-point source programs in particular. Population
is clearly an important factor in estimating future waste
quantities, but the regulations now address the use of projections
in these programs only indirectly.

Don't ruin good things going on in the states right now with too
many regulations. The current level of detail in the projections
guidelines is good now.

If EPA will support a state when it has a strong program, things
will work well. They've built flexibility (the 5 and 10% pro-
visions) into it. If EPA is willing to take the heat, it will
be OK.

The process we used was time-consuming, particularly of staff
time. But because of the local consultatiog, people are
generally agreed to accept the results, at least until the 1980
census.

EPA should look to the states as the "first line of contact”
for resolving conflicts with local governments.

-96-


3.3 USE Of AVAILABLE TIME

among the states which had substantial work to accomplish
to meet EPA's deadline, there was great variation in the
utilization of the available time. At one extreme, there
are five states which admitted or implied to us that they
would not meet the deadline. There are five others that
we believe are likely not to meet it. And there are
additional states that will meet the deadline only if
their last-minute variance requests are approved and without
a public hearing. Some states will meet the deadline only
as a result of providing minimal notice of their public
meetings. Some of these states had hardly or just begun
the process when we spoke with them, even though it was
less than three months before the deadline.

Reasons for lateness typically include communications problems
with EPA, understaffing, too many other things to do, or
problems of jurisdiction within the state.

Other states, however, got off to early starts and used the
time available with great effectiveness. Florida held its
public meetings in January, revised its projections in
tTesponse to those meetings, and submitted its disaggregations
to EPA April 3. _Nevada submitted its variance request in
April. Ohio disaggregated the EPA total to the county level
and submitted these projections to designated agencies and
river basin advisory councils, All but two of the regional
councils submitted revisions that fell outside the allowed
tange. The ensuing process of thorough local review to
achieve acceptable totals for most counties took nine months,
and the state is now negotiating disaggregations for facility
planning areas outside the designated areas. All this was
achieved before some other states had even prepared a work
plan for the process.

Since a draft of the guidelines was in the Federal Register
in early 1977 and since states saw EPA's projection for them
in early 1978, it is difficult to understand why some states
waited until summer 1979 to begin the work.



Region VI (AR, LA, NM, OK, TX) - Dallas
Thomas Lera, 214/767-2624

Region Vil (ZA, KA, MO, NB) - Kansas City
Vig Ziegler, 816/374-3429
KA: Larry Sheridan, 816/374-5429
MO: Gtr.) Lee Duvall, 816/374-5429
NB: John Houlihan, 816/374-5429

Region VIII (CO, MT, ND, SD, UT, WY)- Yenver
CO: Bruce Zander, 303/837-4963
MT: Robert Fox, 406/449-5486 (note area code)
ND, SD: Roger Dean, 303/837-2721
UT: Paul arell, Doug Johnson, 303/837-4963
WY: Mike Strieby, 303/837~4963

A2gr28_ ix (AZ, CA, HI, NV) - San Francisco
AZ: Mark Brucker, 415/556-3793
CA: Loretta Barsamian, 415/556-2833
HI: Kitt Armstrong, 415/556-8085
NV: Rick Hoffman, 415/556-3039

Region X (AK, ID, OR, WA)- Seattle
Mike Gearheard, 206/767-1237

AK: Stan Brust, 907/271-5083 (note area code)

ID: Eldon Edmundson, 208/384-1450 (note area code)
OR: Cecil Ouellette, 503/221-3250 (note area code)

WA: Al Ewing, 206/455-7218

-138-


RAW MEXICO

Contact date: July 25, 1979

Catherine Callahan 1177 estimates 1,190,090
Section 208 Project Manager FPA project fon: 1,436,000
Evironmental Improvement atate projection: EPA 423%
Division (FID) Projection submitted: 77
Health and Environment
Department

7.0. Rox 968
Santa Fe, New Mextco 87503
(505) 27-5271 ext. 297

Stephanie Kruse
Planner E5

Water Quality Planning Unit
Favfronmental Improvement Miviston
Health and Envitonment Departmer
P.O. Box 968

Santa Fe, New Mexico 8750
(505) 877-5271 ext. 368

State Projections.

The Wealth and Favtrooment Department had contracted for the Bureau
of Business and Economie Research (BRER) of the University of New
Mexico to prepare projections through 1990 to the county level using
a demographic model.

Special Activities for ETA

For this process FID contracted with ANER to extend its projections

te the year 2000 and to the level of uasteuater facilities planning
areas. Tor disaggrepation to planning area, BRER wiJI have ao economic
analyst vho will Introduce some economic factors. The state feels
they have a good demographer who knows the state vel! and does pro-
jectLons for wraniim companies.

The county level projections were duc in mid-July, though they were
overdue az of July 19. These were then to be sent to COG's, develop-
ment districts, and those counties which were expected to be particu-
Jarly interested. The responses were then to be sent hack to BRR,
vho would then complete planning area level projections by September
15. Public hearings were then to be held in the Jast two wceks of
September, and then the projections were to be approved by the Water
Quality Contro} Commisaton, which meets onty infrequently, at thetr
next meeting. Offictally the state was planning to met the October 1
deadline, but gave Indications that they were avare that this vas
unlikely. Possibly they will submit draft ftgures by this date and
final figures soon after, though FPA has specifteally written them that
this procedure fe unacceptabl

Upon Inquiry as to why the contract with BRFR vas written with such
a late deadline, FID indicated that it was “between a rock and a
hard place." FID has no demographic expertise and tn the past has
done only perfunctory population work. BRER was essentially their
only contractor, but would not commit itself to an earlfer date.
Looking at the consequences of lateness (step J grants would be
delayed, but the state has few step 1's coming), they dectded to
be late and to have gnod projections.

(New Mexico)

The state has had a troubled correspandence with FPA concerning
procedures for requesting a varinnce. In May of 1978, the state
wrote to the Regtonal Administrator requesting te use the BRER Low
Series year 2000 projection, which fs 23% higher than the BEA year
2000 projection. In June of 1978 FPA wrote back requesting the state
to submit a justification and documentation of public notice for this
variance request. In Septenber 1978 the state sent to the Regional
Administrator a copy of a letter from BBER critiquing the BFA pro~
Jections, but apparently no information regarding public notification
or the basie for their alternative projection. EPA at Jast replied
to this in May of 1979 by apain requesting Justification and doce
mentation of public notice. It is currently the state's intention

to submit the request for a vartance at the same time ns tt submits
ite ufsagerceations. This 1s at least partly because the rtate feels
that tt ts dif{icult to present further Justification without specific
numbers.

There had heen no formal public participation to date, though the
state had been contacted by two Sierra Club people and a few others.
Also, they had briefed thefr 208 policy advisory committee which had
sent back conments.

Other Comments

One Line of reasoning for requesting the large variance is that the
state claims that FPA's number dors not take Snto account energy
development: uranium, coal, ofl, and gas. The AKER critique of
REA‘s methodology argues that:

-121-

1) BEA's projections were based on estimates of per capita income
which were revined subsequent to the release of the poupulation
projections;

2) The projections prior to adjustment for undetenmeration in the
1970 Census were too low, but the estimates of underenumeration
for New Mexico, the largest in the country, were so large as to
render all entimates questionable.

Tt might he borne in mind, hovever, that energy development in such
an atid environmentally nensitive aren Is highly debatable, Rather
than being a foregone conclusion, 1t will depend on various national
and state policy decinions which have yet to be made.

It might be noted that since the entire state In one 208 area, the
requirements for meeting the October 1 deadline would seem to be
simply submission of a projection for the entire state, as well as

for all SHBA's, The planning atea projections would not be required
until six months afterwards, and even then only when the state requests
step 1 grants. Thus, it would seem that 4f the variance ts approved,
the state should be able to meet the October } deadline, but Af the
variance is rejected, the state will be late.


WEST VIRGINIA

Date of contact: August 13

Wigh Fdvards 7/77 estimates 1,859,000
Water Resources Mvfston FA projecti 2,003,000
3201 Greenbriar St. state's projection: none

Charleston, W.V. 25311 projection submitted: 2,034,319

W4/ 348-5902

State Projections,

The Governor's Office of Economic and Commmnsty Development 18 supposed to
Assue official state projections, but said they would have nothing ready by
the dead li

Special Activities for EPA

The rtate didn't have any preexisting figures, so they were stuck with FDA'S
even though they thought the projection For 2000 was a hit Sow.

They sed the 1970 Census and the revised 1976 population estimates, to the
county Jevel, and determined the increase for each area. They then
extrapolated that same share of the growth for each aren through 2000.

There's only one designated agency: around Charleston. Tt was more than 10%
over the state-produced disaggregation, so the state Imited ft to 10Z. We
presume that this accomtes for the difference between the EPA number and

the submlited total. For tvo or three comties the Census Burean eatimates
nhoved a population decrease, however, the Final state projection showed them
having constant population.

They have given notice for holding a public meting. lp to this point there
had been nc participation by the public or Jocal government except for the
one designated area.

Other Comments

The state wJI1 meet the EPA deadline and requirements with no trouble, but
public faput will be minimal,

WASILINCTON
Dates of contact: July 18, 25
Kathleen Carcta 7/77 estimate 3,658,000
Panne EPA projection 4,417,000
Office of Water Programs state's projection: more than 5% over EPA
.

Muntcipal Division projection submitted:

206/753-2971

Jan Whitworth
Planner

Comprehensive Programs Division
206/753-2809

State Projections

The Office of Financial Hanagenent (OTM) does projections, disaggregated to
cities and comttes. The preexisting set was more than 5% aver BEA, and
although Garcia hadn't seen the new ones due July 1, she assumed they'd be
even higher.

Most planning bodies use the OFM methodology and forecasts except the Puget
Soumd Coordinating Council and the tvo Seattle area designated 2085, vhich
have developed their om.

-130-

Special Activities for EPA

They vere hehind schedule. Garcia had been on projections for only one
month, and Whitworth, the other staff person involved, had started only
July 17.

They viJ1 start with OFM's figures and coordinate vith local projections.
Thelr time frome:

August 6 : public notice on meting
August 16: release population projection data
September 6: public meeting In Olympia

OFM's resident expert 9 demographer Donald Pittinger, of University of
Washington.

‘An explanation proferred for the state projections being #0 much higher than
EPA wos that the EPA numbers vere prepared during the Boeing slump, but now
that Boeing is OK, and there is trade with China, the state is growing faster.

Other Comments

The overage in the state projections ts concentrated in the Seattle area.
This could he a problem because, according to one activist, Spokane is
Jncated over a designated Sole Source Aquifer, has urban population
densities but cural plumbing.

The state's planto release the population projections only three weeks
before the public meeting allows inadequate public notice, particularly
since there seems to be controversy in the state over projections.

There have been requests From the public for meetings in Spokane
and in Seattle or Tacoma, since Olympia ts a difficult site for
people other than those employed by state government to Ret to.

Washington seems to be extremely late in tmplementing thin process
and negligent tn involving the public, a situation especially
unfortunate in light of the large and controversial varfance request.




EPL - -

FE am
£

Be
SIERRA
CLUB

530 Bush Street San Francisco, California 94108 (415) 981-3634

September 15, 1979

TO: Environmental Leaders, Activists on Population Projections,
and Others

FROM: Judith Kunofsky, Population & Growth Policy Specialist
and Project Director
Donald Forman, Project Associate

One of the most important, and often ignored, influences
on environmental decision-making at all levels of govern-

é ment is the population projection used. Projections are
used to prepare clean air and clean water plans throughout
the country, to calculate the size of a sewage treatment
facility for which federal funding is available, to assess
the need for and extent of highway expansions or amass
transit, to evaluate costs and benefits of proposed
water diversion projects, to project recreational
needs and forecast energy demand.

Because the use of population projections can in some
ways be self-fulfilling, they are important tools for
those concerned about land use or growth policy.

The way projections are used can help solve - or aggravate -
environmental problems, Construction of a sewage treatment
facility can foster the paving over of prime agricultural
land. The ensuing sprawl development can create new and
worse air pollution and water pollution, and increase energy
use. A water diversion project designed to meet "projected
needs" can cause problems at the source of the vater and
in the basin to which the water is brought. A highway
built to fill projections of automobile travel can take
needed funds - and riders - away from mass transit. ~ ~~
Similarly, by shaping federal investment, the use of
population projections can be a strong influence on the
future of America's cities and towns: They can assist in
economic changes which would not otherwise have occurred.
They can help fund development in parts ¢ an area which
would otherwise have remained undeveloped or, conversely,
help promote the revitalization of a city.

AUG 09 1989


’ 1
LOUISIANA
Date of contact: July 25 7/77 estimate: 3,921,000,
FPA projection: 4,659,900
state projection: 7
Date Givens projection submitted: 77

Assistant Chief

Diviston of Water Pollution Control
Department of Witdlife and Fisheries
PO Drawer FC

University Station

Baton Roupe, Lovissana 70899

(504) 42-6163

State Projections

There are several sets of county level projections including enes done
by the University of New Orleans, and another wmiversity (Loutstana State
Universttv?).

Spectel Activities for ETA

‘The State Planning Office has prepared county projections. These vere
agererated up to basins which are larger than counties except Cor a fow
water quality limited segments. These numbers are used in "303" water
basin plans, as well as jn 208 plans, though it was not clear whether
208 plans already exist or were being prepared.

Givens did not know the state mumbers compared with FPA. He indicated
that they were trytng to stay vithin 5%, but that they may not he able
to and may need a variance. Ne assumed they vould submit in Septomber.

There are eight citizen advisory boards and one other beard. There have
been two public hearings, one on a summary of part of the 208 plan

Some Jocal poaple complained that their projections were too tov, but
there had heen no written response on population.

Except for the Department of Wildlife and Fisherles and the State
Planning O€fice, nocther state agencies have heen tnvolved with
disaggregations, and they von't be used for any other purpose.

Other Comments

We had some difficulty Jorating the responsible person, being referred

from one person to the next.

MAINE
Date of contact: August 13
Bob Nunan 7/77 esttmate: 1,085 000
Dept. of Environmental Protection TPA projection: 1,222,000
State House state's projection: none

Augusta, ME 04333
207/289-2591

Projection submitted: EPA4 4.3%

State Projections

The State Planning Office produces projections for the state. They currently
do not have any for the year 2000, but expect to produce such in Ix to nine
months.

Special Activities for EPA

The State Planning Office vas unwilling to produce the projections and
disnggregations to met the required EPA deadline, 60 compliance with the EPA
guidelines ts being met through projections developed in the Dept. of
Environmental Protection.

The state has told the EPA regional office that the projections which will be
submitted are “interim” ones and that the state plans to resubmit numbers
(with a possible vartonce request) as well as disaggregations in the future.

Projections are produced by regional planning commissions covering the state,
some of which are designated 208 agencies. When these projections are
totalled they sum to “significantly more” than the ECA number. DEP plans to
reduce the projections of those regional planning comnissions which are not
designated 208 agencies in order to get a state total within the EPA
Projection + 4.32.

DEC plans to circulate the proposed projections to some other state employees
and to locel governments before submitting them.

There are no plans for a public meeting.

-114-


4.3 PUBLIC INVOLVEMENT

In this section we discuss involvement of the non-governmental
public in preparing, considering, or evaluating the projections
used for the EPA requirements. It was disappointing to us
that,in many states, our questions about public involvement
were answered exclusively by reference to the involvement

of local governments and it was sometimes difficult for us

to make clear that we were particularly interested in the
direct involvement of the non-governmental public.

It is hard to give an overall assessment of public

involvement throughout the country. In some cases, there

were pre-existing projections which were used widely throughout
the state. Some of the projections in these statas incorporated
clearly articulated policy goals (see section 3.5). ‘lany

were pure "trend" or "baseline" projections (see definitions

in seccion 3.5); of those, some were prepared with the
involvement of advisory committees that included university
representatives (Arizona, for example) or business representatives
(Delaware, for example). «thers were prepared purely by
technical professionals.

Some of these states, which in most cases had little to do

to comply with the enidelines, aré now scheduling public

meetings as the guidelines require (examples: Illinois, Michigan, Minnesota)
Others believe they have already satisfied those requirements

either through public involvement in the projections process

or as a result of hearings on the 208 plans

Most states which prepared projections for the 208 program
reported having included consideration of those projections

in the 208 hearings. In some of those, projections were
singled out as a separate item of discussion - but no state

in this category could recall any of the discussion. In others,
projections were among the subjects on which public comments
could have been made, but generally were not.

-72-


3.7 STATE REACTIONS TO THE EPA PROJECTIONS

By far the most comments from the states on ways to improve
the implementation of the EPA guidelines were on the EPA
state projections. Several states claimed to have not heard
anything about the model or the purpose until they received
the EPA projections "in the mail;" we did not check whether
they meant the original set sent out in early 1977 for their
review or the final set,

The states want more involvement in the process of developing
the assumptions used in preparing the projections. There
were many complaints about BEA's data base and assumptions
being not detailed enough, outdated, or too general. Some
states claimed to have no idea what methods BEA had used to
produce the projections for EPA,

Roughly 25% of the states had either questions about or
disagreements with the BEA model, the final numbers, or the
process of consultation with the states.

wvespite these disagreements, virtually none of the states expressed
objection to EPA's having prepared a set of state projections.

We must admit, however, that we did not ask a direct question

on this subject. Nevertheless the states were being quite

frank with us in general and one might suppose that if they

felt strongly about this issue they would have mentioned it.

We guess that the situation would have been very different

had the 5% "automatic" variance and the procedure for requesting
even greater variances not been available.

Sample comments of state representatives follow:

Communication

Several states complained that communication with BEA about
their model is very difficult or impossible, "To talk with
BEA you need to know the details of their model and that's
almost impossible." BEA is far away and it's "not easy to
complain to them." Furthermore, since "there is no formal
mechanism for EPA and the state to discuss the projections"

of BEA, the state has no effective way to consider or challenge
the BEA methodology.

-56-


DELAWARE,

Date of contact: August B

Jerry Expostto 1/77 estimate 582,000
Unter Resources Section TPA projection: 841,900
Department of Natural Resources and state's projection: less than
Environmentat Control 95% of FPA
Tatnell Butiding. projection submitted: same

Dover, Delaware 19901
(302) 678-5409

State Projections

There 1s a state Population Consortium, an informal group that in accepted
as the state's offictal population and economic estimating group. Tt has
vartable composition -- anyone can come -- but Includes representatives
from state agencies, county planning departments, cities, and Delmarva
(Det.-Hd.-Va.) Power and Light.

The state projections were done in 1975 to the county level through 1995
by the University of Nelavare, Diviston of Urban Affairs. They did ant
include economic varlables to any great extent. The Consortim contracted
with the University to extend these projections through 2000, but this
isn't particularly more accurate, according to them, just an extension

of the old projections.

They have two designated 208 arens. For conrtal Sussex County, tn 1977,
the Diviston of Urhan Affatrs prepared subcounty projections. This in-
volved preparing a ptojection for the whole county, which was much Less
than the older official projections. The consensus of the Consort itm war
to use the new figure, and subtract the difference from the state total,
vhich brings the state total even farther below the EPA projection. The
county had wanted to keep the original higher mumbers.

Special Activities for EPA

Until shortly before we called, the state had heen unaware that thelr
number had to be within 5% of EPA. At the Inst mecting of the Consortium,
thie vas brought up, and people were worried because the state number was
Jover than FRA's by more than 5% and thought that this might be prohibited
by the guidelines. The tate had not yet spoken to EPA shout this.

If EPA says they have to hold a public meeting, they'll do so. They
have put off dealing with dinaggrerations to facility planning arear,
thourh it's been brought up and is on the Consortium's workplan for next
year.

Other Comments,

They were not avare that St is perfectly within the guidelines for the

state figures to he more than 5% lover than BEA‘s, but they hadn't
arked EPA yet.

We had dif(leulty locating anyone who knew about the procens. We spoke
to people in both 208 and construction grants whe did not know what was
gotag on, one of whom even assured us that no one in the state was working
on this.

Although the atate became aware of this process rather Jate, it should
not be difficult for it to comply vith the Octoher I dendiine because it
has preexisting projecttons.

ELoRIMA
Date of contact: August 9

gene Nowak 7/77 estimate: 8,452,000
Environmental Administrator FTA projection: 15,069,900
Bureaw of Wastewater Management and Grants state project tons:
Department of Envtronmental Regulations Tow: 11,909, 110
Tin Towets Office Building medfum: 13,671,350
2600 Blatr Stone Road high 15,401,600
Taljahassee, Florida 32301 projection submitted: 14,857,064

(904) 48-2582

State Projections

In 1978 the Bureau of Economic and Business Research (BBER) of the
University of Florida prepared three sets of county projections using
demographic methodology.

Spectal Activities for EPA

The ETA projections were disaggregated to counties by computing each county's
share of growth from 1970 to 1977 and then projecting that same share of
growth up to the FPA totals. These mmbers were taken to seven public
meetings around the state in early January, The partictpants included locat
Planners, regional planning councils, Zero Population Growth, and reveral
state agencies. The state received 26 requests for deviations covering
Hfty or more of the state's 67 counties. These requests vere analyzed

by an ad hoc group consisting of Nowak, the head of 201, the head of the
non-destgnated 208 group, and the chief demographer from the Division of
State Planning in the Department of Adminintration. The requests were {
mont cases accepted {f the projections were used in the past, and vere used
for other planning functions. Thus, considerable changes were made, and
the numbers Finally submitted to EPA in April, 1979, and accepted by EPA

in June, totalled less than the EPA projections, but more than the BENR
medium figure

-109-

Other Comments

In submitting the projections Florida requested the opportunity to reevalu=
ate them if their use should be extended to other federal agencies, if any
significant regional departure from them should be expertenced of expected,
and after each census. These conditions were accepted by FPA.

Florida vas the first state to submit its projections, yet it managed
while acting quickly to hold an extensive set of public meetings resulting
An quite considerable input, especially From regional government and

also from other state agencies. This input was token seriously and
resulted in real changes in the projections.


2.4 EXAMPLES

EXAMPLE A

Suppose a state has one designated 208 agency, called Metro COG
and exactly one other SMSA encompassing the rest of the state,
called Greater Bigtown. Suppose that the projection the state
has to use is one million for the year 2000 and that the
existing Metro COG projection, being used in water quality
plamming, is 600,000 for that year.

Possibility #1: Give Metro COG exactly the projection it already
has and yive Greater Bigtown a projection of 400,000 for
the year 2000.

However this may be unacceptable to Greater Bigtown, which
itself may have a larger projection or want a larger one.

Possibility #2: Give MetroCOG 91% of its projection, namely
546,000. Then allow Metro COG to get a 10% variance.
In other words, Metro COG can use a projection of 546,000
+ 54,600 which is 600,600; Metro COG can now continue to
use theprojection it wanted. The state now can give
Greater Bigtown a projection of 1,000,000 minus 346,000
or 454,000?

The state winds up being able to use a projection of
600,000 + 454,000, or 1,054,000,

-28-


C, What if a state prepares its population projection by
aggregating (i.e. summing or adding up) projections
prepared initially for substate regions?

The state still must submit any request for a variance from
the state number first.

Quite a few states, including Norch Dakota, Nevada, New York,
Montana, and Utah, are preparing their projections this way
(see Appendix B).

D. Are the state disaggregations supposed to reflect "trends"
or "goals"?

The guidelines do not specify either, although at least one
state mistakenly assumed that the disaggregations were raquired
to be "trend" or "baseline" projections, In fact, sa-eral
states are explicitly including established state goals in
their disaggregations.*

One of the problems with population projections is that equally
qualified professionals could produce different population
projections for the same geographical area; there is therefore
always a policy decision to be made on whose projections are

to be used.

E. Who decides in what circumstances a designated 208 agency
is allowed to use the up~to~10% variance?

That decision, according to EPA, is made jointly by the state
and the EPA Regional Administrator

*See definitions and discussion in section 3.5.

-24-


KANSAS

Date of contact: July 31

Norma Sandberg, 1/77 estimate: 2.326.000
mid-level engineer FPA projection: 2,517,000
Dept. of Health and Environment state projection: 2,629,160
Forbes Field projection submitted: 2,629,160

Topeka, Kansas 66620
(913) 862-9960 ext. 251

State Projections

In 1977 the governor ordered that no state agency could prepare population
projections except for the Division of State Planning and Research of

the Kansas Department of Administration. These aren't ready yet, and in
the Interim the Department of Health and Environment is allowed to use
ther 1974 projections From "303" water basin plans, but it fs not clear
to what degree they may revise them.

Special Activities for FEA

The of fictal projections may not be ready in time for the deadtine and
may not be within EPA's limits; so Department of Health and Environment
dectded to prepare thelt ow projections for counties and cities uring
extrapolatinn From the 1970 Census and the 1976 Census Rurenv extinates.
Because the Census 1977 estimate already exceeds the EPA 1980 projection,
it was decided to use the FPA figures plus 5% as control totals. The
Department has no demographic expertine, and so these profertions ware
prepared by Sandherg, an engineer.

Sandberg emphastzed the weakness of these mmbers and the worry that
someone else might use them for another purpose. In particular, there
is a 14% difference between the new figure for the Kansas City 20R and
that of BARC, the COG (Counct! of Governments). MAR ts currently
preparing the new projecttons, and Sandberg guessed that the correct
number vas probably somewhere between. In late May they sent out a
draft of thetr numbers. On July 2 there wac a public meeting, and a
coment period from then U1] July 16, though they were still accepting,
comments at the end of July. The numbers vere sent to regional planning
commiastons, the Kansas League of Municipalities, consulting engineers,
etc, but not to the interested public, environmental groups, of
population people--because the official projections are expected soon,
she said. They tntend to watt Chl the Last minute for submitting to
HEA. They intend to give EPA the new official numbers as soon ag they
are ready.

Other Conments

Sandberg pointed out the weakness of the projections may not be as much
of a problem as 1t could be, because for three years the state has had
a strong population policy tn terms of revicwing grant applications.

RENTUCKY
Date of contact: July 25
Shelby Jutt 7/77 estimate: 3,458,000
Chief of the Programs Branch — FPA projectfon: 4,224,000
Division of Hater Quality state project ton:
1065 US 127 South Louisville: 4,287,000
Department of Natural Spindletop: 4,506,952
Resources and Environmental Battelle Lab: 4,406 , 79%
Protection projection submitted: — 4,287,000

Trankfort, Kentucky 40601
(502) 564-3410

State Projections

Before EPA's regulations came out the governor had directed the
University of Loulsville Urban Studies Center to prepare projections.
They took the 1970 census data and did a reviston wsing 1977 estt~
mates. Previously there had heen projections prepated for the
state's Department of Transportation by Spindletop in July, 1971

and used for the river basin report in 1975. Jutt thought that the
Department of Transportation might prepare their ow in the future,
or else might use the University of Louisville's.

Special Activities for EPA

The Division of Water Quality looked at the University of Loutaville
projections in Itght of the Construction Grants program and saw few
impacts. They are less than 5% off from the EPA numbers. ‘The state
notiffed EPA of the figures. They held a public review period for
which they notified all municipalities from early May to mid-June.

Ome of the 15 area development districts has {ts own projections which
it wants to use, but the state can't let them because the numbers don’t
agree and the projections don't really affect them anyway because they
are in steps 2 and 3 of grants, and won't need a new projection until
after the L980 Census. One 208 area is disaggregating itself. One is
no longer designated as a planning area; so the state ts disaggregation
At. No other state agencies have been involved.

-113-

The disaggrenation will be included tn the public hearings on the 208
plan. They've held six public meetings on 208 plans, which included
projections. There were fourteen groups that were in various ways
favoived with 208 meetings, including Slerra Club, League of Women
Voters, Appalachtan Plants, a couple other environmental/public interest
groups, and seven area development districts. Fach of these districts
contains an environmental comittee. Five hundred attended the meetings,
but few poke on projections. They expect to submit the disapgrerations
in early August.

These projections will be used for non-point source pollution planning
by the Diviston of Conservation and for solid waste by the Diviston
of Hazardous Materials and Solid Waste Management.

One 208 area may use the 10% variance. The projections throughout
the state are prepared to the facility planning area Jevel.

Other Comments

The state had preexisting projections so that it was easy to meet EPA's
deadline.


44032

or components thereof that meet the
Agency's criterion for such projects.
r, ths does Not mean thal the
must adupt an option featur.
ovative or alternative ‘echnol-
ogies wherever ir monetary costs
are less than the 15 percent cetiing ce-
cause nonmonetary factors must be
taken into account as weil.

Discount vate. The Agency consid-
ered raising tne discount rate for eval-
uating proposed wastewater treatment
hat used dy the Agency
ly % percent) to 10 percent.
The former rate is used by the Water
sources Council (WRC) to evaluate
cests and benefits of sater re-
a member

ie Budi shed the Cost-Elfecty
Analysis Guidelines (appe:
tion Grant Regulations), al-
the construction grants pro-
covered by the WRC
“principles and standards” for evaluat.
ing water resource projects. The latter
ent) is clted in Office of
and Sudget (OMB) cir-
94 for use In agency programs
vered oy the WRC “principles
ang standards.”

2 20-percent rate is believed to ap-
pro imate the opportunity cust of cap-
ital, The “Opoertunity Cost of Capital
Concept” nas the mest theoretical eco-
leation for cost-effective:
This concept suggests
the proper discount rate to use for
pubic investment projects should be
dased on the rate of return to private
sector investment (before taxes and
adjusted for inflation), This is because
resources used for public investment
have alternative uses in the produc-
tien of private commodities which so-
ciety foregces for the saxe of the
public investment.

se of the id-percent discoun’ rate
would help produce 3 miore economi-
cally ent distribution of construc:
tron grant funds. The expected result
is that the optimal (cost-effective)
staging period (the number of years
for which the treatment plant {s de-
signed to handie a community’s
growth in terms of sewerage dis-
ebarge) will cecrease from about 10-29
years to about 9-16 years. These
shorter staging pestods will result in
slightly smaller treatment works and
im smaller mitial treatment expendi-
tures for each proposed treatment
system, This should permit 2 some-
what greater number of treatment sys-
tems to be funded.

Despite these considerations, the
Agency has decided against raising the
discount rate to 10 percent. The
higher discount rate would have the
effect of lowering the total present
worth cost of facilities with high oper-
stion and maintenance costs mm com:
parison with the total present worth

shougt
OM is not

FEDERAL 2ZGISTER, VOL 43, NO.

RULES AND REGULATIONS

cost of capital intensive facilities with
low operation and maintenance costs
such as land treatment and energy re-
covery facilities. This could largely
offset the 15-percent cost-effectiveness
preference given to such measures
unger the 1977 Act and these guide-
lines. It would also run counter to the
President's recent decision to retain
the existing discount rate for water re-
sources projects.

Many commenters representing a
wide variety of interests opposed in-
creasing (he discount rate (only one
favored such action) primarily because
I actions would tend to disadvan-
tage capital intensive land treatment
and energy recovery alternatives and
would favor operation and mainte-
Rance cost intensive options.

The Agency has decided to retain
the WRC discount rate (currently 6*4
percent) because this rate is consistent
with the President's water resources
policy and the net programmatic ad-
vantages, if any, of increasing the rate
are not of overriding importance.

Cost escalation. Several commenters
advocated use of a salvage value for
land higher than the = pr
market price as required in the inter-
un guidelines because of the very high
rate of land value appreciation. The
Agency has analyzed farmland value
appreciation since 1960 and since 1970
and has compared these rates with
cest escalation rates for construction,
energy and iabor. The analysis showed
that land values over both the (7-year
and T-year periods have escalated
roughly 3 percent faster than costs as-
sociated with construction or oper-
ation and maintenance of a treatment
works. On this basis, the final guide-
lines will require, {n the calculation of
land salvage value, 2 land appreciation
rate of 3 percent compounded annual-
ly, unless the grantee Justifies 3
higher or lower percentage Dased upon
Yustorical differences between local
land cost escalation and construction
cost escalation. This allowance repre-
sents the estimated difference In rates
detween land cost appreciation and
the cost escalation of goods and ser-
vices related to construction.

Several commenters suggested esca-
lation of energy, chemical, and labor
costs in the cost-effectiveness analysis
to account for articipated high in-
creases in these costs. It should be
noted that the cost effectiveness anal-
ysis procedures cal! for use of constant
dollars based on prevatiing market
prices at the time of the analysis anda
low discount rate which is less than
the inflation-free rate based on the op-
portunity cost of capita! concept. This
approach, rather than implying no
future Inflation, simply assumes that
the costs of all resources involved in
treatment works construction and op-
eration will increase at about the same

-37-

D\ SCUSSION

rate on a long-term basis. The results

of the cost-effectiveness analysis
would be distorted, now uf the
prices of certain resource inputs

hanged stgmificantly over the plaa-
ning period in relation +a the prices of
other resources. The Agercy has ana-
lyzed hustocic data on wastewater fa-
e:lity construction price indexes and
om prices of Varfous operation ani
maintenance componefts, including
labor, electricity, chemicals, coal, pe-
troleum distillates, and natural gas.
We also reviewed provections of fut
energy use prepared by the Depart.
ment of Energy. Only the historic and

projected increase in natural gas
prices were found ‘to significantly
exceed (by nearly 4 percent) those for

construction and average of other
on and meenance elements.
the Agency has revised the
3 to require escalation of reta-
tive natural gas prices over she
ning period at a compound rate of +
percent annually, urless the grantee
justifies a higher or lower percentage
based upon regional cifferentials be-
tween historical natural 733 price esca-
lation and construction cost escale
tion.
Reserve cavacily}

The Clean Water
Keency, in deter
Ing the amount of reserve capacity #!
gible for a grant, to take into account
the prosected poguiation presented in
a facility pian. @ population must
be based on the iatest information
available from the US. Denartmenc of
Commerce or from the States as EPA
determines appropriate, The interim
guidelines called for population fore-
casts in facility plans to be Dased upon
disaggregation of State population
totals already developed by the De-
partment of Commerce. Several com-
menters, principally 203 planning
agencies, oppose this approach and
contend that population forecasting és
a policy matter that should best ae ad-

te]

dressed by local governmental units.
Others, principally environmental

groups and individuals, favor the dis-
aggregation approach as a means of
preventing excessive capacity and re-
sultant secondary impacts.

The Agency believes the diseggrega-
tion approach should be retained be-
cause, to avoid providing excessive re-
serve capacity, forecasts of population
and economic activities for individual
small areas such as facility planning
areas or designated 208 areas snould
be reasonably consistent with State
and national projections, This ap-
proach is consonant with the Presi-
dent's urban policy intended to revital-
iwe cities and discourage urban sprawl.
The guidelines permft inclusion of
extra capacity in a treatment worss at
the expense of the grantee to accom-
modate local growth policies, The final
guidelines allow reasonable departures

—_

188—WEDNESDAY, SEPTEMBER 27, 1978


NORTH DAKOTA

Date of contact: August 13

Francis Schvindt 1/77 estimate: 653,000
State Health Department FPA projection: 690,900
1200 Missourt Avenue state's projection: within 5Z
Bismarck, ND 58505 projection submitted: Same

701/224-2354

Richard Blair, Director
Office of Statistical Services
Department of Health

State Capitol

Bismarck, ND 58505

‘
According to Blatr, the state had a program to produce population project tons,
but appropriaticns ‘ran out Jn June, 1979. Several yearn ago they produced
nine demographic projecttons, with varying fertility and mgratton assunpt fons,
down to the reglonal planning and comty levels. An interim set of state
numbers were issued, which mipht still he used hy most agencies. There are no
official state nunbers.

According to Schvindt, projections were developed as part of the 208 process
by local agencies, presumably the eight regional plmning comcils, one of
which Is a designated 208 agency. State-developed guldeSines were wed to
Produce those projections.

Eight public hearings vere held on the 208 plan and no others are scheduled.
The projections in the 208 plan total to within 5% of the BEA munber.

Other Comments

We could not determine the relationship beturen the earlter set of
state-produced projections and the ones being used in the 208 process.

aire
Date of contact: August 13

Eva Hot teman 7/77 estimate: 19,791 ,000
Onto EPA EPA project Lor 121031000
Office of the Planning Coordinator state's projection: 1?

361. Broad St. projection submitted: Tess than 5Z over FPA

Columbus, Ohto 43215
614/466-BB60

State Projections

The state has 1974 and 1978 HUN projections and a sat de by a consultant
for the Department of Health (this Last used a combined methodology).
agencies have opted for one set or another. To met WUD requirements this
situation must be resalved by September 1, and negotiations are under way.
Ohio EPA's (a state agency) 1s the only projection with stroug local input.

Spectal Activities for EPA

‘There were preexisting 208 projections in the designated areas, but these were
much too high; they took up 90% of the state's gravth, so Ohio EPA prepared
nev projections. They started vith the EPA total plus 5% and did a cohort
nurvival projection for counties to this control total.

They then submitted these projections to designated agencies and advisory
comells for each river basin, They Jet the regional councils revise them as
long as they maintatned a regional control total. Al) but two of them fell

outside the alloved range, and so vere forced to revise domvard. ‘
ria)
The Dayton metro area requested a 200,000 decrease. They documented it vel), a

so Oho EPA granted it. If a county or region could document a change from
the projection, it was accepted.

This process took nine months, but this state agreed on county totals, except
for three or four counties which they are RtiJ} working on. They had very
thorough Local review and Loca} input. They then used their data base to
develop Egures for the EactIity planning ateas. They have just produced
those and sent them for local review to the non-designated areas. Designated
areas are preparing disaggregations for themselves.

The submitted number will be close to 5% over EPA's projection, but the exact
total is not known yet, becauce there are two regional agenctes left to deal
with,

The advisory committees include most environmental groups, and the state
technical advisory committee includes the Sierra Club, League of Woren Voters,
ete. The only non-governmental groups to respond have bean chambers of
commerce, universities, and some people vho do projections.

They used a demographic mode! for the county projections hecause they did not
have adequate data Cor econonetric models for rural areas, but some regions
that had good deta used econometric models for thetr further disaggregat ions.

They will moet the October 1 deadline for comty level projections. They
expressed concern that they would not meet that deadline for facility
planning erea projections, and indicated that this vas @ matter of concern
for them due to some regulations on "forming designated management agencies”.

Other Comments

The state appears to be doing an exceptional job of getting local involvement,
which they take sertously but not merftically. They ore avare of the mix of
demographic and political isaves involved and are working tevards workable
compromise.


believe they are growing very rapidly - generally in response
to decisions made by the federal government - and that special
consideration should be given to frequent updates or

perhaps even interim adjustments in projections for parts

of the state (see section 3.10).

Some states had prepared their projections before the guidelines
were issued, either for their own use or in specific response

to Clean Water Act requirements, but did not prepare disaggre-
gations to the now required geographical detail,

Approximately seven states mentioned their lack of enthusiasm
about preparing projections when the 1980 census is almost
here.

-62-


NEW WANPSIU RT,

Date of contact: August 17

Janes Mebaugh tin 7/77 estimate: 849,000
Of flee of State Planning EPA projection: 1, 306,000
1 1/2 Beacon Street state's projection: 1,207,000
Concord, NH 03301 projection submitted? 1,207,000
609/271-2155

Also" Dave Nevill, Water Supply & Pollution Control Division

State Projections,

The Offlce of State Tanning produces demographir projections at the state and
regional Jevels; projectlons for municipal{ties are then produced using Jand
-use information. There are no policy assumptions used. A major revision was
Assned in Avgust 1977.

Regional planning agencles are involved in preparing the projections, with some
Input from the towne. Other state agencies are also involved, but not the
public. AL} state agencles use these numbers.

Special Activities for EPA

There is a working agreement between OSP and the Water Supply and PelJutton
Control Mision. The FactIittes planning evel 1s in most cases the same as
the town level.

The three designated 208 agencles have used the OSP numbers.

McLaughlin was unfamitiar with the EPA projections guidetines, but fs in the
Process of getting more details from the Water Supply & Pollution Control
Division

Other Comments

New Hampshire vas one of the states vhere the state's oun projection ts less
than EPA's and there is already use of those projections in 208 planning ~and
a5 8 result none is paying much attention to the guidelines. Nelther of the
tuo people we spoke with was very familiar with the guidelines. However,
except Cor a possible need for a public mecting ft would appear to be very
simple for the state to comply by sinply formally submitting its projections.

1 2
WeH_JéRsEy

Date of contact: July 23

Joseph Wiley 7/77 estimate: 7,329 000,

Office of Areawide Planning FPA projectton 8,747,000

Diviston of Water Resources

Dept. of Environmental Protection
1474 Prospect St.

£20. Box GH 029

Trenton NJ 08625

State's projection: 9,066,000
projection submitted: 9,066,000

State Projections

Demographic projections are prepared by the state's Department of Labor and
Industry. Those vere adjusted upwards to reflect potential development fn
two particular uthan comties, resulting In a projection for the state of
9,066 ,000.

Spectal Activities for ECA

Originally, the state had trend disaggregations vhich were being reviewed hy
citizen advisory committees. In the middle of the process tt was changed to
be a policy-orsented process, with the state producing project tons which

reveal its intentions, to be folloved by public review of those intentions.

Three policy assumptions are guiding the disaggrepations: Urban areas should
atabilize their populations at the 1975 levels. Undeveloped areas should
have a drastic cutback in their rates of growth. Suburban areas should
continue their current moderate growth rates. The state is considering
possibly using the projections which arise from these assumptions to channel
state investment.

These projections were released and sent to EPA in June 1979 tn draft form.

Although some of the projections prepared by designated 208 agencies are
Rreater than those produced by the state for this process, the state will not
Fequest variances and the 208 agencies will need to revise their projections.

Public meetings on the projections will be combined with hearings on tne 208
Progran.

Other Comments

Although at least ove Interested citizen attempted in early 1979 to find out
who in the state was responsible for compitance with the EPA guidelines om
Projections, he was msuccessful despite having made six or seven calls. At
that time, staff in both the Rept. of Environmental Protection and the
Governor's office (wiich has nominal authority) stated they were not the
appropriate agencies.

Nevertheless, New Jersey appears to have heen the most farsighted and
Innovative in ite use of the guidefines. It remains to be seen haw the
citizens advisory committees and others in the state react to the projections
being developed and the assumptions undersying them.

-120-


E. Consideration of the Impact of the Projections

Statewide discussion should be fostered of the impact of

the projections used, As one state official commented, people
understand what the projections mean only as they consider

the impact of the numbers and distribution on water quality,
housing, land use, open space, jobs, air quality, etc.

It is no wonder that much of the public is not interested

in projections abstractly: divorced from considerations of
impact, the numbers are much more difficult to grasp.

One state official commented to us that his agency was
obligated to prepare the projections, but that he hoped some
other state agency would consider the impacts, some of which
he thought were adverse.

-83-




General Negative Comments

It's sensible to use different methodologies for different
purposes. The Federal DOT projections have been useful to us
and in the short term they have come out very close. I caution
against using one set of numbers for all putposes.

There will be a similar problem with the OMB plan to the one
the states now have with the locals, The states are likely to
say that there's not enough state involvement.

Projections are not appropriate for allocating money.

Joint BEA/Census projections (to be proposed by OMB and Commerce)
might not be better. Ome small state commented that it was
difficult for them to ave influence. A larger state suggested
outside review in developing the projections.

We are "headed for a big battle with OMB." States know the
trends better than the feds. The OMB proposals don't take into
account federal policy objectives such as Carter's urban policy.
If we look at the long-term situation, for example, the northeast
has plenty of water and will get more growth.

If done wrong, this could reinforce current population shifts
around the country (which is bad).

Other Comments

You nesd to look at the implications of using different projections.
Overbuilding of hospitals, for example, causes higher rates to

its patients but overbuilding of highways brings no complaints
because it wasn't built with local money.

All calculations of need should be done straight, with a safety
factor added explicitly at the end. The way it's done now, they
add a safety factor in each calculation, and the final number is
wildly inflated.

In non~EPA programs, one has to get the analogue of per capita

use and the design period. One fact that also needs to be considered
is the risk. For example, in the case of hospital needs, coming

up short is a real problem.

-102-


The Conference Committee version, which was integrated
into the Clean Water Act, amended Section 204 (a) (5) to
add the following to the section quoted above:

+s. at a date when such capacity will be required

“after taking into account, in accordance with regu~
lations promulgated by the Administrator, efforts to
raduce total flow of sewage and unnecessary water
consumption. The amount of reserve capacity eligible
for a grant under this title shall be determined by

the Administrator taking into account the projected
population and associated commercial and industrial
establishments within the jurisdiction of the appli-
cant to be served by such treatment works as identified
in an approved facilities plan, an areawide plan under
section 208, or an applicable municipal master slan of
development. For the gurpose of this paragraph, section
208, and any such plan, projected population shall be
determined on the basis of the latese information
available from the Unitéd States Department of Commerce
or from the States as the Administrator, by regulation,
determines appropriate....."

In compliance with this requirement, and following the
ideas developed in the earlier published draft, EPA issued
interim regulations implementing the Clean Water Act of
1977 on April 25, 1978. These included, in Appendix A,
cost-effectiveness guidelines with a section on population
projections, and went into effect June 26 of that year

After a comment period, a final set of regulations for the
Construction Grants Program was frinted in the Federal
Register on September 27, 1978. These contained the
guidelines on population projections which are the subject
of this report. A copy of the guidelines and the Federal
Register discussion of comments received on the earlier
drazt is in section 2.5.

-1ll-


5.2 PUBLIC MEETINGS ON PROJECTIONS

(see section 4,3)

In many states, the public meetings on the disaggregations
wexe combined with meetings on the water quality plans.
Although this has the benefit of focusing attention on che
impacts of growth rather than on the numbers themselves, in
most cases the projections were never the subject of
comment.

EPA should suggest to the states that, when holding meetings
on a number of subject, population projections be specifically
given a special place on the agency and their importance
highlighted for those attending.
Furthermore, EPA should strictly enforce the following:

* holding of a meeting when required

* adequate public notice

* calculating the time of issuance of public notice only

from the date materials are available to be reviewed

by public, not merely when a notice is published

* scheduling msetings in accessible locations at times
during which the public can attend without difficulty

*

scheduling meetings sufficiently before submissions

deadlines to allow public concerns to be evaluated
and incorporated into the state's proposals.

-84-


Because the process has thus far been tied only to

certain environmental planning requirements, the agencies
overseeing the process have been either environmental ones
or what we have been calling "projections agencies." I£
the process were implemented to cover many more federal
programs, presumably the latter agencies would get

greater responsibilities and the former less.

However it is »recisely the "projections" agencies which
in many states have no interest in or knowledge of public
participation. We believe that requirements for public
involvement must be carefully and tightly written and
enforced, because the risk of lack of public invo.vemenc
is greater.

We recommend serious consideration of states establishing
state advisory committees on projections with mandatory
membership of a certain number of non-governmental
individuals including varied backgrounds in all the relevant
program areas: water, air, solid waste, housing, educacion,
transportation, etc., as well as population.

Leaving such options open to the states is likely to be
productive only in those states which have thus far displayed
public participation in implementing the EPA guidelines.

Several states complained that they were not sufficiently
consulted when the BEA/EPA projections were developed. In
two cases the estimates used were not comparable to those
used by the states. Such problems should be taken seriously,
and opportunity for state involvement should be created.

The various federal planning requirements should be spelled
out on a timetable and the relationship of development of
the projections to that timetable should be made clear to
the states, Otherwise there may well be rampant confusion
about which update of the projections is required to be
used by whom, when. The particular cases of states whose
am projections timetables are incompatible with required
state updates for federal purposes should be dealt with

in advance,



1.1 SIERRA CLUB INVOLVEMENT IN POPULATION PROJECTIONS

For several years the Sierra Club has been interested in

the use and abuse of population projections in federally-
funded programs, The Sierra Club has sponsored a continuing
program of training its members and involving them in the
issue of population projections.

Projecting the numbers of people expected to live in a
region and the distribution of their homes and jobs
around the region is one of the important components

of developing air and water quality plans. The numbers
and their distribution affect transportation patterns
and automobile use; the amount of water used in lawns

and gardens; runoff problems associated with construction
activities; the number of dry-cleaners and attendant air
pollution; the amount of area covered bv pavement and

therefore possible problems with drainage of stormwater,
etc.

In general, the higher the projection, i.e., the greater
the population, the more difficult it is to meet any
particular set of standards. This is because there are
more people whose activities can produce pollution.

The distribution of population, though, is also very
significant. For example, a population living in
suburbia and commuting with automobiles to jobs would
produce more air pollution per person and in total than
if they were living more compactly and used buses, or

if they commuted shorter distances by automobile,

In at least some cases in the past, communities used
different projections for different purposes. This was

not only confusing and a possible waste of money and dupli-
cation of effort, but also was not a good way to meet
public needs: Use of different projections might direct
growth in different ways, thus cancelling the impact of
both the programs. Or one program may be using projections
to calculate needs for certain public services, while
another program causes growth to occur elsewlere in the
community. Thus, the first program's efforts are not

only useless but expensive.


NEBRASKA

Date of contact

Susan Noppel 1/77 estimate:
Natural Resources Conmisston EPA projectton
7.0. Box 94876 state's projectio
Lincoln, Nebracka 68509 projection submitted:
402/471-2081

1,561,000

State Projections

The State Office of Planning and Programming (recently renamed Policy Research
Office) handles projections. The above listed state projection was sent to
by citizen contact ax the medium sertes of thelr 1976 projecttons.
may be amore recent one. The actual work seems to he contracted to
Wiversity of Nebraska Bureau of Business Research.

Special Activities for EPA

OPP's most recent update was
Projections go to cities (r
comtles

ender the 208 planning process. The
Rhly equivalent to facility planning areas) and

Although she f= the person coordinating the process,
the regulations ti} a week ago, and did not know al
participation req)
specifically on p

lope] vas umavare of
tthe publte
The 208 process involved many hearings, but none

Other Coments,

Presumably they can met the deadline by promptly scheduling 9 public meting.
It fs conceivable that thelr 208 process may already have satisfied the require-
mente technically, but it surely does not somd Itke on effective vehicle for
public participation 1 those attending were not notified of the connection of
the hearing with this process.

NEVADA

Date of contact:

Bob Rigsby 7/77 estimate: 633,000
Sentor Urban Planner EPA projection: asa
State Planning Coordinator's Office . 1,585,000

state's projection
Capitol Complex projection submitted: 1,585,000
Garson City, NV 89710

State Planning Coordinator's Office. Nefore that time, several agencies prepared
projections.

The model 1s a demographic and econometric one for the comties, and the
projections are summed to the state level.
December 1978. Local governments vere not very involved in the development of
these projections.

Special Activities for EPA

The state requested a variance at the end of April. A notice was published in
the three major newspapers and sent to each major city and other state agencies.
There was no response to the neuspaper notices.

He is working with the three designated 208 ag
projections.

fes to reconcile the

Disaggrerations to the comty leve) were submitted to FPA but only in tentative
form. They will hold perhaps three public meetings in September prior to
submitting the final disaggregations.

Nevada was the first state to submit its request for a variance and is to be
applauded for having dealt with this so much sooner than many of the other
states viuich are only now submitting such requests.

The notice of the request which was published in the newspapers might
gotten some response had it also been sent to environmental groups, I
not to have been done.

-119-


5.9 URBAN AREAS WITH DECREASING POPULATIONS
OR LOW GROWTH RATES

(see section 3.7)

A major weakness in the guidelines is that while they

May prove to Le effective in preventing overbuilding, they
are not very effective in those areas which, from a variety
of criteria, should experience more rapid growth.

If one takes the trends in, for example, many urban areas,

one sees substantial decreases in the center city population.
This provlem could be resolved if the states were to realize
that they need not use “trends” in producing the projection;
they could instead, as New Jersey is doing, establish goals
for population in urban areas and have the projections reflect
those goals. We have addressed this more general problem
elsewhere in the report.

Nevertheless the problem remains when we look at the state
projections; they have deen prepared according to "trends" for
the states, and the process does not appear to allow this

to change. The only opportunity would seem to be for a stute
itself to produce a higher overall projection and convince
EPA that such is the “real” trend,

Since these regulations are considered to be part of the
President's Urban Policies, effects on our established cities
should be carefully considered.

We recommend that a thorough analysis be done of how population
projections are used in making funding decisions throughout

the federal government and, in particular, how this affects
urban areas.



MARYLAND

Date of contact: August 7

Larry Forelzon 2177 estimate: 4,139,000
Adminssteater J (applications person FPA projection 5,583,000
rather than demographer) state's projection: within 12

Maryland Department of Planning
301 W. Preston St.

Baltimore, Maryland 21201
COV) 383-2465,

Projection submitted: same

Department of Planning has been doing state projections for more than

ten years, using a demographic model. they are trying to he on a two year
schedule, althongh they have been somevhat irreputar fn the past. There
is no law that anyone mist use their figures (though there are thoughts
of enacting one), but they have tried to get them adhered to with some
stice Tut other agencles may use other fipures. The Health Department
produces short-range forecasts.

Alen, since L966 they have required county water and sever plans that
say where antl when service vill be. They don't have statutory authority,
but the state share of sewer Funding gives come leverage. Thetr procedure
ts to develop county totals. Tf a comty uses a mmber different from
thers, they want to talk, and thelr Leverage through grants gives a

de facto pover of approval.

In the future they antletpate a more open and cooperative method for all
planning areas -- an advisory group of state agencies and countins, lots
ef chance for local input. In counties vhere the county's own total
doesn't agree with the state's, they will have te have negotiations over
the subcounty totals. They have submitted pleces of their projections
over time since Lad fall, and EPA approval will be at varying times,

by drainape bain.

Special Activitses for EPA

They are using thelr preexisting projections, meeting, public participation
requirements by Including the projections {n 208 plans; there are 11 or 12
non-destgnated area hearings over this sumer. In designated areas they
negotiated acceptable numbers. Apparently there has been no response
from the genera) public, environmentalists or population groups.

It sounds Uke the state has a long-standing serlous projections effort
that will meet the deadline with no trouble. Tt is not clear, however,
to what degree the public has an opportunity to be genuinely involved.

MASSACHUSETTS:

Date of contact? August 27

Made Line Snow, on behalf of: 7/77 estimate: 5.782000
Linda Simto, Planner FPA projection: 6,614,000
Dept. of Environmental Quality Engineering state's projection: 6,668,000?
00 Cambridge Street projection submitted: 7,054 ,0677
Boston, MA 02202

State Projection

In 1975, the then-existing Office of State Timning prerared a projection Sor
the state for the ycar 2000 of 6,668,000 and disaggregated the projection to
the level of the thirteen regional planning agencirs.

The projections at the state level were demographic projections.

No single set of projections was used hy all atate agencies. Novever, former
Governor Dukakis instituted a policy of having consistency, and Governor King
has continued that policy. Movever, there Ls no state agency currently dealing
with projections except for those vith environmental planning responsibilities.

Each of the regional plonning agencies considered the projection and in sone
cases revised it slightly, then disaggrepating further to smaller geographical
areas. They vere required to hold metings with local elected offictals and
consulted with citizens advisory committees.

-115-

This process was part of implementation of a state Growth PolicyAct, passed in
1975, and which resulted in a Massachusetts Grovth Policy Report Issued in

Seplenber 1977. Extensive meetings and discussions were held throughout the
state at all levels of povernment.

At the local level, the projections apparently reflect a commitment to
revitalizing of cities ond towns, curtailing of sprav) and protection of
ogricultural Land, and thereby incorporate policies, not simply trends.

The total of the projections finally adopted by the regional planning agencies
4s 7,054,067 for the year 2000. Of the thirteen regional planning agencies,
wine were designated 208 agencies over at Ieast part of their areas. The
Projecttons developed as above were used tn the 208 water quality planning,
both by the designated agencies and the state.

The Dept. of Environmental Quality Engineering {s now dovble-checking the
Projections vith local governments and is using a computer system of the
Division of Air and Hazardovs Materials. After this rechecking and review the
state will then decide whether or not it needs to request a variance from EPA;
the current projection of 7,054,067 1s slightly more than 5% greater than the
EPA projection.



A.4 SPECIFIC SUGGESTIONS OR PROBLEMS

This section covers ideas not included in earlier chapters
or in the State Reports.

One state felt the 5% and 10% variances were “arbitrary” and
that if such variances ere allowed at the state and 208 level
they should also be allowed at the facilities planning level.

Two states commented that treating the designated and non-
designated areas differently (as far as possible variances)
polarizes them and is unfair to the nondesignated areas,

One state commented that because the 10% variances allowed

to the designated areas do not take population away from other
parts of the state, it is politically impcssible for the
Governor to refuse to grant one. (%n the other hand, several
states in which there are significant differences between the
208 and the state projections are not going to grant the
variances and have no problems with that)

One state accepted a 5% variance even though it really wanted
a somewhat larger one because the process was easier.

One state has several problem counties which contain large
military bases. They have to rely on the army's figures for
those but there may be closing of bases in aQher states which
would mean more people in their state.

Five states mentioned having communities with large seasonal
populations of tourists and retired people and not knowing
how EPA wanted them to handle this in their projections.

One state commented that since most of the step 1 grants in
that area have already been awarded the guidelines should
perhaps also cover step 2 grants. Related to this is the
following:

In one state the current set of projections is now significantly
different in parts of the state from the former set. One lagge
project is now completing its planning phase (step 1 grant) and

it appears that the projection which was used is very much inflated
compared with the more recent projection. Ome person in the state
government stated a preference for having the most recent projection
used even if it is developed at the end of a lengthy and expensive
planning process. That state had attempted to get the contractors
to consult regularly with local government planners but this
apparently was difficult to implement.

-100-


BPE
BORE

eee
ee  ernenneNSeeenrenl
CHAPTER 4

SUMMARIES AND CONCLUSIONS: INVOLVEMENT WITHIN THE STATE

Coordination Among State Agencies
Involvement of Substate Covernments
Public Involvement

What Remains to be Done

Cee een eee enna eneneneeereaennetenneerg seen anareesnaoeesneasnssssssnssanussensnensssuase=sssenng



3.10 ENERGY-IMPACT STATES

Much of the dissatisfaction with the EPA process, and with
the EPA state projections in particular, came from energy-
impact states: Alaska, Colorado, Utah, Wyoming, Montana,
New Mexico. Wyoming, for example, updates its projections
every six months and was concerned that if frequent revisions
to the projections used by EPA are not permitted, planning
will be done and facilities sized based on patently outdated
projections.

States with "boom towns” were particularly concerned chat
"locking" a town into a previously-prepared county projection
is not productive.

Furthermore, states appear to be using different philosophies
in determining what energy-related facilities should be
assumed in preparing the projections, even under a "baseline"
or “trend series. One claims not to include any project
unless it isunder construction or the environmental impact
statement has been approved. Another may perhaps be including
all projects proposed in the President's energy message ,
vegardless of the likelihood of their being carried out.

One state expressed frustration with having to prepare and

submit only one projection, since they believe the state
population in the future will to a great extent be determined

by national decisions which have not yet been made. That

state suggested that states be allowed to submit an "alternative"
projection which would come into use if a particular scenario
does materialize. The concerns expressed in this suggestion
might, in our opinion, be easily alleviated if appropriate
larrangements are made for quick revision of a state's pro-
jection should conditions change quickly.

In quite a few cases we asked for ideas on how EPA might

best deal with the problem of energy-impact states or towns.
Ideas included allowing frequent revisions of the state's package
of projections, allowing updates of projections for a particular
sudstate region if that area has grown more than a pre~
established amount, having a certain "pool" of populacion which
is not allocated to any state which would then be available to
energy-impact areas if needed.

-60-


making such a request, the state must issue a public
notice of its intention to do so. The Regional Administrator
of EPA must then "solicit public comments and hold a pnlic
hearing if important issues are raised about the State
projection's validity." EPA regulations require a 45 day
notice for a public hearing, which can be recuced by EPA to no
less than 30 days if the longer notice "is not needed to encourage
public participation " in that hearing.

C. Disaggregating the State Projection

After it has been decided what projection the state will use,
the state must prepare a "disaggregation" of that projection
to parts of the state. A disaggregation is a division of a
projection into projections for smaller geographical areas.
It is sometimes called an "allocation",

The particular geographical areas in the state for which

a projection must be prepared are described in the guidelines
and depend on how the state is doing its water quality planning
under the Clean Water act.

The state must determine a population projection for each of
the following substate areas:
a) each designated 208 agency (see section 2.1)
b) outside designated 208 areas, for each SMSA (Standard
Metropolitan Statistical Area) and "all non-SHSA
counties or other jurisdictions." (see definition in 2.3)
The sum of these projections must not exceed the state projection.
It can be lower if the state wishes.

The state must prepare its disaggregations in consultation with
air quality planning agencies, designated 208 agencies, and
other regional planning agencies.

We have found that in some states the agency in the “lead"
position is the one responsible for water quality planning;

in some it is the agency which prepares population projections
for the state; in others it is a more general policy or
planning agency (see section 3.4).

The dissggregations must be sulmitced to EPA by October 1, 1979
However before the state submits them, the state must hold a
public meeting on the subject. Federal regulations for the
Clean Water Act require no less than a thirty day notice for

a public meeting.



my,

Of the states whose disaggregations were "baseline", some
used elaborate demographic or econometric models, while others
did not. One state, for example, compared with 1970 census
results with the 1977 estimates and simply extrapolated the
growth trends from that period. When asked if they really
expected the areas to grow at the same rate for the rest of
the century, the state replied that that's the best they

have.

Ome state commented that since "there are no well-documented
disaggregation methodologies except for land-based ones

which are complex and require massive data,... we fall back on
a quasi-technical and quasi-political process, which may be
OK but which many planners don't like because it doesn't
produce a pure projection.”

We believe that two states are likely to present EPA with
projections which include mere arithmetic manipulation of the
numbers, reflecting neither technical rationales nor state
growth policies,

-51-


In some states, though, problems within the state hamper the
development of such consistency. Some are discussed in other
sections of this reporc (see, for example, section 3.4). In
one state, all planning is done with the same statewide popu-
lation projections, but different programs use different
disaggregations. In another state, one agency prepares county-
level “trend” projections while several others use the regional
planning agency projections because the latter are tied into
air quality and water quality planning and reflect aore closely
local land use constraints and decisions. One state has four
sets of operating projections: two for HUD programs, one done
by a consultant for health planning, and an environmental

set. Only the latter, according to our state contact, has had
strong local input.

Two states complained that consultants and/or municipalities
"can't be forced to use the same projections," despite the
state being the source of the program's money. In one of
those cases, the state had attempted to ensure that the
consultant work regularly with the regional planning body;
iowever that proved impossible to enforce and is now causing
substantial problems. Despite these states' experience,
others nave no similar problems ensuring the use of state~
produced projections by substate governments.

-535-


5.7 REVISIONS OF THE PROJECTIONS AND
INTEGRATION WITH OTHER FEDERAL REQUIREMENTS

(see sections 3.6 & 3,11)

EPA should make clearer determinations of how revisions to
the state projections and the disaggregations can be
integrated into ongoing envircnmental planning efforts.

EPA should also resolve with the Dept. of Housing & Urban
Development the relationship between projections prepared for
EPA's 208 program, ncw in some ways constrained by these
guidelines, and projections used for HUD's "701" plans.

5.8 EARLIER DEADLINE FOR VARIANCE REQUESTS

Several states are delaying the submission of variance

requests until close to October 1 and submitting them together
with disaggregations, This has the result that if the variances
are denied, these states will not have submitted adequate
disaggregations.

Furthermore, such late submissions make it difficult for
public reaction to the variance request to be adequately
considered and incorporated,

These situations could be avoided if the deadline for requesting
a variance of the state number were considerably earlier than
that for submitting disaggregations.

~87-


CHAPTER 2

THE EPA GUIDELINES ON THE USE OF POPULATION PROJECTIONS

The most “accurate” description of any set of regulations or
guidelines is, of course, the original text itself. However
in this case, where the guidelines are in smail type and
tersely written, a more leisurely explanation is certainly
warranted. We here present,first, a two-minute version,

the Federal Register discussion of comments received in
response to an earlier draft, and then the text of the
guidelines themselves.

2.1 A Two-Minute Version of che Guidelines
2.2 A Ten-Minute Version of the Guidelines
2.3 Further Questions

2.4 Examples

2.5 Discussion in the Federal Register and Text of the Guidelines

-15-


3.9 COMMUNICATIONS PROBLEMS

Many states evidence substantial confusion over what was
required of them, even on questions clearly dealt with

in the guidelines. This may have been because they did

mot read the guidelines carefully enough (or, in some cases,
at all), because the guidelines were perhaps too tersely
written, or because of insufficient or confusing communi-
cations with EPA staff.

We point out the following to identify the typical problems:

Ay

Some states were unaware that anything needed to be done
at all, In some cases these were states whose projections
processes were sufficiently consistent and complete that
little, in fact, needed to be done. In others, the states
needed to hold a public meeting or sometimes undertake
substantial amounts of work, One state observed that it
relies on IPA to highlight for it what needs to be done;
that they do not have sufficient staff to pore through
new regulations.

There was much confusion over what needs to be submitted

to EPA by October 1, although the guidelines are clear on
this point. Several states, believing that projections
were needed down to the facility planning level dy October,
mistakenly thought’ they would be unable to satisfy EPA's
requirements, .

Several states mistakenly believed that the 10% variances
available to designated 208 areas must fit within the
original state total,

Some states mistakenly thought that the EPA process is
connected with the upcoming OMB/Commerce proposals
(see cover letter, and sections 4.4, Appendix A.5, and
elsewhere), and one state delayed its disaggregations
waiting for word about the OMB/Commerce process.

Some states did not know that a public meeting was
required. This was true not only in states where a
"projections" agency was carrying out the requirements
but also in a few cases where an "environmental" agency
was in charge.

-59-


Chapter 5:

VCC RU Meme)
NAW ONE

boo

UuUY
°

Appendices

Appendix A:

RECOMMENDATIONS page 79

State Activities to Involve the Public

Public Meetings on Projections

Communications Between EPA and the States

Written Guidance for the States

States Which Have Had Difficulties

Involvement of Other State Agencies

Revisions of the Projections and Integration with Other
Federal Requirements

Earlier Deadline for Variance Requests

Urban Areas “ith Decreasing Populations or Low Growth Rates
Proposed Fedezal-Wide Process

ADDITIONAL COMMENTS OF THE STATES page 93

General Supportive Comments

General Negative Comments

Miscellaneous Commencs

Specific Suggestions or Problems
Reactions to possible Federal-Wide System

Appendix B: INDIVIDUAL STATE REPORTS 103
Appendix C: GLOSSARY 133
Appendix D: EPA CONTACTS 137
Appendix E: "Population Projections: How They Are Made ... And 139

How They Make Themselves Come True”, reprint from Sierra


* Many scates have not yet prepared the projections
to the facility planning level, which will soon de required
for areas submitting step 1 grant applications. These
projections need considerable local involvement.

* EPA is developing regulations to tie together in a
consistent way the projections used in clean air planning
and the impact of the construction of sewage treatment facilities.
Public involvement is needed in commenting on the proposals
for this effort, which is iiplementation of Section 316 of
the Clean Air Act, and in implementation at the local level.

* Many states are involved in trying to establish
statewide consistency in their use of projections.

* Many states have regular projections processes, and
these involve more or less frequent revisions of projections
for the state and substate levels.

~78-


EXAMPLE B

Suppose a state is working with a projection of one million
for the year 2000, as in Example A. But suppose the state

now has two designated 208 agencies called Metro COG and

Area COG and that everything else in the state is part of
Greater Bigtown, an SMSA. Suppose that Metro COG and Area COG
have been using projections of 500,000 each for the year

2000.

Clearly, the state can't produce a disaggregation with
500,000 each for Metro COG and Area COG because there would
be nothing left for Greater Bigtown, not even the current
level of its population.

Possibility #1: Suppose one of the designated 208 agencies
has also prepared a population projection lower than
the one they eventually chose to use for the 208 process.
Give the 208 that projection and see if enough is
left to satisfy Greater Bigtown,

Possibility #2: Give both Metro COG and Area COG 91% of
their original projections, or 455,000 each. as in
Example A, "give" each area its 10% variance, bringing
them back to roughly 500,000 each. The state now
has left to allocate 1,000,000 - 455,000 - 455,000, or
90,000. If this is acceptable to Greater Bigtown,
the state's problems are solved.

If this is not acceptable to Greater Bigtown or to the

state, for whatever reasons, the state has no choice

but to a) give Metro COG or Area COG even lower projections
b) request a variance of the state number from EPA.

Possibility #3: Suppose the state already has a set of
projections for regions or counties, or perhaps several
sets. If one set gives a total projection of roughly
one million, the state could allocate population according
to that projection. Or, if the state has county pro-
jections totalling, say, 1,200,000, the state could give
each of the three areas under consideration 83% of the
sum of their constituent counties’ projections,

-29-


——_ (0) 23,000-uaut miadiewncoma rousing daveiooment.”

Successful Activities Towards Public Involvement

Despite the preceding fairly bleak account of public

involvement throughout the country, quite a number of the

states did engage in activities which we believe are appropriate
for stimulating participation. We believe that if such
activities are incorporated into projections procedures

through the years, they will encourage the development of a
public following which will be able in the future to make
significant contributions. And an additional and immediate
benefit is that most of these activities have been highly
successful in generating the involvement of local government:

* Massachusetts had an extensive growth policy process.

* Florida held seven meetings around the state solely on
population. ©

* New York will publish a detailed handbook on projections
for local contractors.

* New Jersey is using the process as a forum for articulating
growth policy, one which will then will be widely discussed.

* Arizona has cniversity planners and demographers on its
technical advisory committee.

* Hawaii has an ongoing Commission on Popnlation and
Hawaii's Future.

* Ohio spent nine months negotiating over the county
level projections, has held fourteen public meetings, and is
now negotiating over projections for facilities planning areas.

“nmen would you rather see ouilt an tnia ste?
(a) Animterconuinental atcert. 3) an atomic
pewerpiant: (Ci a maitvee snopaing center: 3¢

|



4.2 INVOLVEMENT OF SUBSTATE GOVERNMENTS

In producing population disaggregations there is no substitute
for interactions among the various levels of government. The
federal government has to deal with states who have to deal
with counties and COG's and 208's, who have to deal with
municipalities.

"It's a negotiating process. You don't jam a population
figure down a throat."

This kind of negotiation is necessary to get accurate base
data or desirable trends; it is also needed to get the
adherence of local governments to the projections once produced.

Fortunately, this kind of intergovernmental contact is also
highly desirable for reasons that go far beyond projections.
It is the keystone to effective regional planning of all
kinds, and to effective implementation of almost any state
program.

So we see it as a bonus that states with effective projections
mechanisms in the course of them achieved considerable contact
with different layers of government.

Ohio was exceptional in its efforts in this direction:

"We're kind of proud of what we've done, Local communities
vealized that this will determine the size of their
facilities and so they took it seriously.... We submitted
(our county projections) to designated agencies and advisory
councils for each river basin. We let the regional councils
revise them as long as they maintained a regional control
total, All but two of them fell outside the allowed

range, so we forced them to revise downward.

The Dayton metro area requested a 200,000 decrease. They
documented it well, so we granted it.... If a city or
county could document for us a change from our projection,
we accepted it.

This process took us nine months, but we agreed on county

totals except for three or four counties which we're still
working on. We had very thorough local review and local
input. I travelled all over the state,

-69-


E, Submitting the Projections to EPA

When the state's disaggregations are ready, the state must
call a public meeting. EPA regulations require no less than
thirty days notice for a public meeting.

Many states have combined these meetings with hearings on the
208 plans. Other have scheduled separate meetings. Still
others, which already had projections developed separately
from the 208 process believe they complied with the public
meeting requirement in their initial development of those
numbers (see section 4.3 for further comments and analysis).

The projections, revised if necessary, are then submitted
by the states to EPA "as an output of the statewide water
quality management process," i.e. the 208 process. In some
states, those plans and the projections were submitted in
draft or final form many months ago.

F. Using the Projections

After the projections disaggregations have been
approved by the EPA Regional Administrator, they are supposed
to be used in the following ways:
1. for future 208 planning
2, for future "needs surveys", conducted every two years
by EPA
3. for the cost-effectiveness analysis, and then the
size of a particular sewage treatment facility whose
facility plans are "prepared under step 1 grant assistance
awarded later than 6 months after Agency approval of the
State disaggregations.” (A step 1 grant is the first
one awarded by EPA for developing the plans for a facility)

G. Projections for Facility Planning Areas

In some cases, the projections the state prepares will not be
down to the level required for planning a particular facility.
Timetables for preparing those projections are discussed in
section 2.3H below.

H. Revising the Projections

The guidelines say that "State projections and disaggregations
may be updated periodically in accordance with Agency guidelines."

-22-


44088

to have « ealvave value at the end of the
planning period a least equal tu ils prevail:
ing market values (he Gre of tne analysis,
In cak ulating the svvage value of land. the
Jand value shall be appreciated at a com:
pound rate of 3 perm nt annually over tne
pisnning period. univ s the Regional Ad-
muinistralor determines that the grantee nas
Justified the use of a grcxter or lesser per:
centage based upon fist: tical aifferences
detween local land cost esetlation and con-
struction cost escaiatiea. ‘Thi land cost esca-
lation rate may be updated perodica:
accordance with Agenc7 yuideines. Right-
of-way easements shall be considered to
have a salvage value mot ureater than the
prevailing market value a¢ the me of the
analysis,

(2) Structures etil be assumed to have a
salvage Value If tnere is a use (ar them at
the end of the planning period In (nis case,
salvage Value shall be estimated using
straignt line deoreciaiion during the useful
Ie of the treatment works.

(2) The method used in paragraph $hi2
may be used to estimate saivage valuc at (he
end of the planning period {or phased addb
trons of process equioment and auxiliary
equipment,

(4) When the anticipaced useful life of a
facility Js less than 20 years (for anaiysis of
Interim faciifties), salvage value can be
claimed for equipment if it can be clearly
demonstrated that a specific market of
reuse opportunity will exist.

7. Innovative and alternative wastewater
treatment processes and techniques.

a. Beginning October 1, 1978, the capttal
costs of publicly owned treatment xorks
which use processes and techniques mesting
the eritenta of appendix E to this subpart
and which have only a water gailution con-
trol function, may be eligible if (he present
worth cost of tne treatment works 1s tot
more than 118 percent of the present worn
cost of the most cost-effective pollution con-
trol system, exclusive of collection sewers
and interceptors common (o the two sys
tems being compared, by 115 percent,
except for the following situation,

b. Where innovative or alternative unit
processes would serve in lew of conventional
unit processes in a conventional taste Sater
treatment plant. and the present worth
costs of the nonconventicnal unit processes
are less than $0 percent of the present
worth costs of the treatment plant, multiply
the present worth costs of the replaced con-
ventional processes by 115 percent, and add
the cost of nonreplaced unit processes.

¢. The eligibility of multipurpose prosects
which combine » water ‘pollution ecntrol
funetion with another function, and 3 hich
use processes and techniques meeting the
criteria of appendix © to this subpart. shail
be determined In accordance with guidance
issued by the Administrator.

“4, The above provisions exclude individual
systems under § 35.918. The regional Admin-
istrator may ailow a grantee to apply the LS-
percent preference authorized dy this see
tion to facility plans prepared under step 1
grant assistance awarded defore October 1,
1978

RULES AND REGULATIONS

3%. Cost-effective staging and sizing of
treatment works,

@. Population proyections (1) The disag-
gregation of State projections of populanen
shall de the basis fur the population fore:
casts presented in individual facility plans,
except as noted. These State orajccuons:
shall be those developed in 1977 by the

Bureau of Economie Analysis (BEA), De-
partment of Commerce, uniess, as of June
28, 1978. une State nas already prepared
projections The State projections may de
used instead of the BEA proje tions if the
year 2000 State population aovs not exceed
that of the BEA projection by more than 5
percent. If the aifference exceeds this
amount, the State must cither justify or
lower its projection. Justification must de
based on the historical and current trends
(eg. energy and industrial development.
military base openings) not taken into ac-
count In the BEA projectinas. The State
must submit for approval to the Administra.
tor the request and justification fcr use of
State projections higher than the BEA pro
yections, By that Gme, the State shall issue
A public notice of the request. Before the
Administrator's approval of the State aro-
yection, the Regional Administrator shall so-
Wert public comments and hold a pudlic
hearing {{ important issues are raised about
the State propection’s validity. State projec:
trons and disaggregations may be updated
periodically in accordance with Agency
wuidelines,

(2) Each State, working sith designated
208 planning agencies. organizations certl-
fled by the Governor under section 1744) of
the Clean Air Act, as amended, and other
restonal planning agencies in the State's
pondesignated areas, shail disaggregate the
State population projection among Ita desig-
nated 208 areas, other standard metropell-
tan statistical areas (SMSA's) not Included
tn the 208 area, and non-SMSA counties ot
other sporcoriate jurisdictions, States that
had enacted laws, as of June 26, 1973, man-
dating disaggregation of State population
(olus ta each county for areawide 208 pian-
ning may retain this requirement. When
disaggregating the State population votal,
the State snail take into account the pro-
jected population and economic activities
identified in facility plans. areawide 208
plans and municipal master pisns. The sum
of the disaggregated projections shall not
exceed the State projection. Where x desig:
nated 208 area has, as of June 26. 1978, al-
ready prepared a population projection, it
may de used if the year 2000 population
does not exceed that of the disaggregated
projection by mare than 10 percent, The
State may then Increase its population pro
jection lo Include all such variances rather
than lower the population projection total
for the other areas. If the 208 ares popul.
forecast 10 percent
aliowance, the 208 agency must lower Its
the allowance and submit
the revised projection for approval to the
‘State and the Regional Admunistrator.

(3) The State projection totais and the
disaxgregations will be submitted as an
output of the statewide water quality man-
agement process. The suomission shall in-
clude a lst of designated 208 aress, all
SMSA's, and counties or other units outside
the 208 areas. For cach unit the disaggre-
fated population shail be shown for the
years 1980. 1999. and 2000. Fach State will
sudmit its projection totals and disaggrega-
tions for the Resional Admunistrator’s =D
proval before Octoder 1, 1979 Before this
submission, the State shall hold a public
meeting on the disaggregations and shall
Brovide public notice of the meeting consist
ent with part 25 of this chapter. (See
$35 917009.)

(4) When the State projection totals and
disaggregations are approved they shall de

used thereafter for areawide water quality
manaxement plannuig as well as for facility
planning and the needs surveys under sec:
tlon $16(D) of the Act. Within areawide 208
pianning areas, the designated agencies, in
consultation with the States, snall disaggre-
gate the 208 area projections among the
SMSA and non-SMSA areas and then disag-
Rregate these SMSA and nomSMSA projec:
ions among the facility planning aress and
the remaining areas, For those SMSA's not
included within designated 208 planning
areas, each State, xith assistance [rom ap-
propriate regional planning agencies, shall
disaggregate ihe SMSA projecticn among
the facility planning areas and the remain-
ing areas sithin the SMSA, Tne State shail
check the facility planning ares forecasts to
ensure reasonableness and consistency with
the SMSA projections.

«3) For non-SMSA facility planning areas
not included in designated areawide 208
areas, the Stare may disaggregate popula-
tion projections for non-SMSA counties
among facility planning areas and remain-
ing areas. Otherwise, the grantee is to fore-
cast future population growth for the facilt-
ty planning area by linear extrapolation of
the recent past (1960 to present) population
trends for the planning area, use of correla.
tions of planning area growth with popuia-
on growth for the township, county of
other larger parent area population, or an-
other appropriate method, A population
forecast may de raised above that indicated
by the extension of past trends where likely
impacts (¢.g,, sigrificant new energy devel-
opments, large new industries, Federal in.
stallations, or institutions) Justify the dif:
ference. The facilities plan must document
the justification. These pepulation forecasts
should be based on estimates of new em-
ployment to be generated. The State shail
check individual population forecasts to
insure consistency sith overall projections
for non-SMSA counties and justification for
any difference from past trends,

(6) Facilities plans prepared under step 1
grant assistance awarded later than 8
months after Agency approval of the State
disaggTegations shall follow peouistion fore.
casts developed In accordance with these
quidelloes,

0, Wastewaler flow estimates (1) In deter.
mining total average day Mow for the
design of treatment works, the Nows to be
considered include the average daily dase
flows (ADBF) expected [rom residential
sources, commercial sources, inst:tutional
sources, and Industnes the works will serve
plus allowances for future industries and
Nonexcessive — inftration/inNow. = The
amount of nonexcessive infiltrauionsinfow
not included in the dase flow esumates pre
sented herein, is to be devermined according
to the Agency guidance for sewer system
evaluation or Agency policy on Leatment
and contre! of combined sewer overflows
(PRM 15-44),

(2) The estimacion of existing and future
ADBF, exclusive of flow reduction from
combined residential, commercial and insti-
tutional sources, shall be based upon one of
the following methods:

(a) Preferred methad, Existing ADBF |s es.
timated baved upon a fully documented
analysis of water use records adjusted for
consumption and lasses of on records of
wastewater Mows for extended dry periods
less estinated dry weather tfutration,
Future Moos for the treatment works desien,
should be estimated by determining the ex-

FEDERAL REGISTER, VOL £3, MO. 188—WEDNESDAY, SEPTEMIER 27, 1973

-40-



3,11 TIMING OF THE REQUIREMENTS

Many states expressed concern about the timing of the
requirement for the disaggregations in relation to the
timing of other processes in which states are also involved.
Some of the problems relate to timetables imposed by federal
requirements while others involve internal state timetables.

Other Federal Requirements

How do these guidelines affect projections used in 208 slans
already submitted and approved? New York has explicitly
discussed with designated 208 agencies which projections must
be updated and under what timetables. However we do not
know if other states, in which plans of 208 agencies must be
revised, have thought this through clearly.

What_is the relationship with HUD "701" plans? Under an
interagency agreement between EPA and the Dept. of Housing &
Urban Development, projections used in the latter's "701" plans
must be the same as those used in EPA's 208 plans. Who

follows whose lead?

How will the process be affected by the release of a new set
of BEA projections in 1979? by proposals of OMB/Commerce?
See 2.24, I, and J.

State Timetables

In some states, an update of the state's own projections is

almost, but not quite, ready. Those states, which include
Maineand Connecticut do not believe that what they submit by
October 1 will be very useful and some expect to resubmit disaggre-
gations soon thereafter. However there is no way that any

fixed timetable for submitting projections would satisfy all the
states, Illinois, Indiana, and Kansas are also about to

release updated projections.

Other states, particularly those growing very rapidly, were
concerned about the June 1978 date mentioned in the guidelines
as the date by which a set of projections must have been in
existence in order for it to be submitted to EPA without a
variance request. They, as well as several other states,

-61-


F. Do the 10% variances available to designated 208 agencies
have to be included in the 5% variance available to states?

No, The guidelines specifically say they do not: "Where a
designated 208 area has, as of June 26, 1978, already prepared
a population projection, it may be used if the year 2000
projection does not exceed that of the disaggregated projection
by more than 10 percent. THE STATE MAY THEN INCREASE ITS
POPULATION PROJECTION TO INCLUDE ALL SUCH VARIANCES RATHER
THAN LOWER THE POPULATION PROJECTION TOTALS FOR THE OTHER
AREAS." (emphasis added)

This is the most widely wnisunderstood provision of the
guidelines (see section 2.4 below).

G. Can the state projection be more than 5% lower than EPA's?

Yes. The state's projection can be as low as it likes. The
guidelines talk about the need for a variance only when the
state's projection is higher than EPA's.

In fact, quite a few states have submitted or will be submitting
projections lower than EPA's, See Appendix B for examples.

H. What must be done after October 1?

Paragraphs (4) and (5) in the guidelines describe what
additional disaggregations must be prepared after EPA approves
the ones submitted by October l.

The specific reference to another deadline is in paragraph (6)
which states that, "Facilities plans prepared under step 1
grant assistance awarded later than 6 months after Agency
approval of the State disaggregations shall follow population
forecasts developed in accordance with these guidelines."

Certain of the additional disaggregations are required (within
designated 208 areas and within SMSA's which are outside 208’s)
while others are optional (outside both SMSA's and 208's).
Projections in these latter areas need to be prepared only in
conjunction with a particular facility plan.

(An SMSA, or Standard Metropolitan Statistical Area, is a metro-
politan area containing at least one city - or twin cities -

of 50,000 or more population, the county in which it is located,
and any adjacent counties that are both metropolitan in character
and socially and economically integrated with the central city.

A list of SMSA's is prepared by the U.S. Office of Management
and Budget.

-25-


We shouldn't have to do disaggregations at all since our
state's growth is totally a function of federal decision.

We would prefer to submit two projections not one. In many

parts of the state, the economy is dependent on one industry

or one company and it is difficult to pick a particular future.
. Having additional projections ready and approved means one

can aitch to using that projection as soon as a decision is

made. This is particularly importance when situations are

changing rapidly.

-98-


3.4 LOCUS OF RESPONSIBILITY WITHIN THE STATE:

All but seven states seem to have basically one agency

which prepares projections for the state, according to our
telephone interviews. We will be referring to these as

the "projections agencies’) Of the seven states which do not,
six have no such agency and one has two of them, one of

which prepares projections for federal programs and the other
for instate use.

In the 43 states with projections agencies, the projections for
compliance with EPA requirements were prepared by or through
that agency in 37 cases. In the six states remaining ( Ca,

KA, ME, NJ, OR, WV), in which the projections agency was

Rot utilized in this process, the reasons were among the
following:

* The state projections agency does only trend projections
and its work does not represent the administration's policies
on the use of projections in state or federal programs.

* The state is using the process in order to implement a
state growth policy, a function not appropriate in that state
to the agency which prepares the projections.

* The projections agency was in the process of preparing
projections, but those would not be ready on time.

* The water quality people wanted to use the projections
prepared by designated 208 agencies rather than state-prepared
projections.

In 7-8 states we had difficulty identifying a person who could
be said to be responsible for the state complying with EPA.

In four states where we eventually found such an individual,
it took us many calls to locate the person. In some cases where
we were able to locate the right person, other individuals in
those states who attempted to do so on their own had great
difficulty and sometimes never succeeded. See section 4,3,
Public Involvement.

-48-


APPENDIX A
ADDITIONAL COMMENTS OF THE STATES
In our telephone interviews we offered states the opportunity
to make whatever comments they wished on the EPA projections
guidelines. In Chapter 3, Summaries and Conclusions, we

have quoted or mentioned many of those comments.

In this section we present additional comments which did
not fit anywhere else or are more general.

A.1 General Supportive Comments

A.2 General Negative Comments

A.3 Miscellaneous Comments

A.4 Specific Suggestions or Problems

A.5 Reactions to Possible Federal-Wide System

Doser enrenranunsss nuangpeansnannnnsunnssnanseesanasneraryersassyeaurenesssssessenseassssamrsensessnenasensr
SS



A third interagency ramification of this process is that

it is intrinsically related to land use and thsrefore relates
to the work of whatever land use or planning agencies a

state has. This kind of contact was frequently realized
because in many of the states the initial disaggregations
were prepared by a state planning agency which then gave

them to the water agency, which often modified them and
handled public and local government participation.
Unfortunately, however, it is not clear that the "planning"
people were always informed of the actual impacts of use

of the projections; often they seemed co be simple technicians
preparing numbers. For other interagency problems, see
section 3,6.

”

The reader may have noticed a certain pessimism on our

part regarding effectiveness of coordination among state
agencies. But we must note that there were six states which
gave indications of efforts to achieve this. For example:

* Quite a number of other state agennies attended
Florida's Tallahassee projections meeting, including the
Division of Forestry, Dept. of Transportation, Dept. of
Health Planning & Development, and the Dept. of State Planning.

* The state projections in Delaware are prepared by
the Population Consortium, which includes representation from
the Dept. of Transportation; Office of Management, Budget,
and Planning; Dept. of Development and Housing; and the
Dept. of Health and Social Services.

* California has an interagency group on population
projections which has met occasionally over the past few
years and more recently has discussed California's compliance
with the EPA guidelines. The air quality and water quality
agencies have both been particularly involved.

-68-


-94-


VERMONT
Date of contact: August 27
Steven Syz 7/77 watimate: 483,000
Water Quality piviston FPA project Lon: 607,000
Agency of Fnvironmental Conservation state's projecttlow* 646 BOO
Montpelier, VT. 05602 project ton submitted:: 646 ,A00

902/828-2763

Bob Wanner
State Planning Of ce
Pavilton Bldg. , Sth floor
Montpelier, VT 05602
802/828-3326

State Projections

Offictal state projections are prepared by the State Planning Office. The
most recent set In the result of a process begim tn October 1977, Drafts
were distributed in 1978 and a set was published tn Jime, 1979. This
projection 4x 646,800 in the year 2000.

‘The projections are now used by all state agencies and local governments,
although that was not the case tn the past.

The projections use a demographic methodology, and are disaggregated to the
county and town levels. Other state agencies vere Involved, such as the
Department of Health. :

Special Activities for EPA

The entire state Is one designated 208 area, Because the state has no SHSA'S,
the EPA guldelines require them to rubmit only one number, namely the
projection for the state.

On Septenber 6 there will be 9 combined public hearing md meeting of the 208
board to discuss the projection a5 well as other vater quality Lssves.

Although the projection was submitted to EPA in early August, Syz did not
realize the state may have to request # variance. ile {s currently checking
the guldelines to determine vhat the state will do.

VIRGINIA

bate of contact: August B

Robert Griffis 7/77 estimate: 5,135,000
Economie Research Sect ton EPA project fon: 6,755.00
Department of Planning and Budget state's projection: 3.1% Jower than TMA
I9L 9th St. Office Rul lding projection submitted: sane
Richmond, VA 23219

804/786-7771

State Projections

Department of Plauning and Budget has responsibility for developing of ficial
Projecttons to be used by all agencies. The atatewlde Economic Base Studies
Frogram develops projecttons, which are sent out to 19 or 15 people in each
county once # year. There is a sertes of meetings vith local governments
and planning commissions invited. Rach planning commission Is asked to
contact focal governments.

Ther methodology is primarily economtc and also demographic. The Research
Triangle Institute 1s involved through 3 contract.

The State Water Control Board made the submission to EPA. The 208 fs
constrained to use Department of Tanning and Budget's figures. The policy
at the State Water Control Board is that when you submit one facility plan,
you bring a plan for the vhole county.

Other Conments

-129-

The state had a well enough developed system for atate projections that they
had no trouble meeting EPA requirenents.



SS aa
——_————$—$—$——————————KK———K—K—<$K—K———  ——————————— I
APPENDIX C

GLOSSARY

In this section we try to define or describe some of the
more technical terms used in the report.

Types of Population Projections

We generally describe the projections used as being demographic,
econometric (or economic), a combined approach or a ratio or

trend projection (see section 3,5 and the State Reports). A
demographic projection makes separate assumptions about fertility,
mortality, and migration and calculates a future population.

It is also called a "cohort-survival" or "cohort-component”
projection.

An econometric projection begins with a forecast of jobs.

Then, by making assumptions about the labor-force participation
rate and the unemployment level, translates that ‘nto a
projection of population.

A combined approach uses both demographic and econometric elenents,
and can be of various types. A common one bases the migration
assumptions in the demographic model on that part of the pro-
jected labor force which cannot be met by locally-born individuals,

Some states use various kinds of trends or extrapolations, and

continue an area's rate of growth into the future (see Idaho)
or an area's proportion of the state's growth (see Alabama).

201 Facility/ 201 Plan/ 201 Projection/Construction Grants Program

Section 201 of the Clean Water Act establishes a program of
federal funding of 75% or 85% (in certain cases) of the
construction costs of publicly owned sewage treatment facilities.
The area which a particular facility is being designed to

serve is the "facility planning area." The population projection
used to plan the facility is the "201 projection." The plan is
the "201 plan." Etc.

These facilities take care of "point sources" of po_lution, i.e.
those coming out of or from a pipe or similar area.

The ssegram in EPA's Office of Water and Hazardous Materials

which makes the grants for these facilities is called the
Construction Grants Program.

-133-


44022

{6560-01}
Title 40—Protection of Environment

CHAPTER I~ENVIRONMENTAL
PROTECTION AGENCY

CFRL 981-8)

PART 35S—STATE AND LOCAL
ASSISTANCE

Subpart E—Grants For Construction
of Treatment Works

AGENCY: Environmental Protection
Agency.

ACTION: Rule.

SUMMARY: This is a conformed ver-
sion of reguiations governing the con-
struction grants program for munici-
pal wastewater treatment works. The
substantial changes in the regulations
serve several purposes. The majority
of the changes implement amend-
ments to the Federal Water Pollution
Control Act (FWPCA or the Act) as
amended, contained in the Clean
Water Act of 1977 (Pub, L. 95-217 or
the 1977 Act). The regulations aiso
contain a series of technical amend-
ments that make technical, admunis-
trative, and programmatic changes to
facilitate administration of and par-
ticipation in the program. The regula-
tions incorporate certain requirements
and incentives to implement the pre-
treatment program for industries con-
tributing to municipal wastewater
treatment works. To enhance public
involvement in the program, the regu-
lations add public participation activi-
tues in the development of State proj-
ect priorities as well as in the approval
of State-prepared population projec-
tions in the cost-effectiveness analysis
guidelines, Cost-effectiveness analysis
guidelines are completely revised to re-
flect provisions of the 1977 Act and
other major policies. Finally. in re-
sponse to Executive Order 12044 on
improving government regulations, we
have made numerous editorial changes
to make the regulatians more under-
standable,

DATES: These final rules are effective
on October 1, 1978, unless otherwise
specified in particular sections. They
apply to grants (including subsequent
related projects) awarded on or after
that date, Comments on changes pro-
posed to §35.936-13 will be accepted
until November 30, 1973.

ADDRESSES: Comments submitted
on these regulations may be inspected
at the Public Information Reference
Unit, EPA Headquarters, Room 2922,
Waterside Mall, 401 M Street SW.
Washington, D.C., between 8 a.m. and
4:30 p.m., on business days. EPA-pre-
pared summaries of the comments are
aiso available. Comments on proposed

RULES AND REGULATIONS

changes to §35 936-13 should be sent
(in tripileate, if possible) to Mr. Alex-
ander J. Greene, Director, Grants Ad-
ministration Division, Attention: PM-
216-P “Subpart E,”" Environmental
Protection Agency, 401 M Street SW.,
Washington, D.C. 20460.

FOR FURTHER INFORMATION
CONTACT:

Michael B. Cook, Acting Director,
Facility Requirements Division
(WH-547), Environmental Protec-
tion Agency, 401 M Street SW.
Room E1137D, Washington, D.C.
20460, telephone 202-426-9404.

SUPPLEMENTARY INFORMATION:
Certain regulatory changes to imple-
ment the 1977 Act were published on
April 25, 1978, in the Pemeru Rects-
TER as interim final regulations. These
included changes related to State pri-
orities, grant eligible categories, land
eligibility, user charges, industrial cost
recovery, grants for individual sys-
tems, combined step 2 and 3 grants,
training facility grants, Buy America,
cost-effectiveness analysis and reserve
capacity. We published these regula-
tions as interim final and generally
made them effective on April 25, 1978,
because they implement provisions in
the 1977 Act that were effective upon
enactment and because they were nec-
essary for ongoing administraticn of
the program. Some of the technical
amendments, which were pubilshed in
Prveral Recister on June 2, 1978, as
the proposed rules, made changes to
the same sections. The provisions can
be distinguished by reading the discus-
sions.in this preamble and referring
back to the earlier PeperaL REGISTER
publications, where the regulatory
changes are set forth section by sec-
tion, The remainder of the regulatory
changes that implement the 1977 Act
were proposed on April 25, 1973, de-
cause, under the 1977 Act, they are
not effective until October 1, 1978, or
because their implementation was not
crucial to the program's operation.
These include provisions on Innovative
and slternative technologies, recre-
ational, and open space uses, and the
provision of assistance by EPA to
grant recipients with respect to con-
tacts.

EPA conducted extensive public par-
ticipation activities in the develop
ment of these regulations. Prior to int
tial publication of any of the regula-
tions in the FxperaL Recister, EPA
circulated four drafts of the regula-
tions implementing the Clean Water
Act, Also in the drafts were changes
on pretreatment and public participa-
tion. We conducted numerous meet-
Ings to solicit public input. These in-
cluded 4 days of open meetings in
Washington, D.C. six briefings for
State and local officials held at EPA
regional offices, and meetings for EPA

(Inte oduct son )

advisory groups. Three meetings were
held with State representatives ap-
pointed by the Nationai Governors’
Conference and by the Association of
State and Interstate Water Pollution
Control Agenctes. Two meetings were
held with the Association of Metro-
politan Sewerage Agencies, two meet-
ings were held with the Management
Advisory Croup, and presentations
were made at the government affairs
seminar of the Water Pollution Con-
trol Federation. We consuited repre-
sentatives of Federal agencies infor-
mally. During this prepublication
period of 4 months we received over
1,000 written comments from State, re-
gional, and municipal agencies: envir-
ornmental and special interest groups;
and the public generaily. We circulat-
ed one draft of the vechnical amend-
ments to 1,000 organizations and pri-
vate citizens before publication in the
PErnerat RecisTER.

On April 25, 1973, EPA published
proposed and interim finai regulatory
changes to implement the 1977 Act, to
modify retreatment requirenients,
and to add certain public participation
activities, On June 2, 1978, EPA pub-
Ushed technical amendments to the
construction grants regulations as pro-
posed rules. After publication of the
reguiations, several environmental and
special interest groups coordinated
five areawide conferences cn the regu-
lations In Atlanta, Chicago, Dallas,
Philadelphia, and San Francisco.
These meetings were attended by
1,000 peopie.

During June, EPA regional offices
conducted 14 public meetings to 5: it
comments. The EPA officials responsi-
ble for development of the regulations
made presentations and answered
questions. The regional offices encour-
aged participation by 2 combination of
press releases, mailings and telephone
contacts to interested and aifected cr-
ganizations. EPA Officials directly Te-
sponsible for the regulations met in-
formally with representauves of other
Federal agencies, environmental, and
special interest groups. They also an-
swered innumerable telephone !nquir-
Ses about the regulations. EPA re-
ceived over 250 comments on the April
25 regulations and over 45 on the tech-
nical amendments published on June
2. These comments and summaries ar
available for inspection at the EPA
Public Information Reference Unit at
the address listed above.

Using the comments received during
and after the comment period, EPA
revised the Apml 25 regulations. We
mailed the revised draft to more than
930 groups, agencies and persons that
commented on prior drafts. We re-
ceived quick responses irom various
groups and considered their comments
TM preparing the final regulations. Be-
sides the revisions to the April 25 reg-

FEDERAL REGISTER, VOL. 43, NO. 188—WEDNESDAY, SEPTEMBER 27, 1978

-34-


This report has been prepared with a variety of audiences

in mind. We are primarily addressing citizen activists
around the country, whom we hope will become more involved
in the development and use of population projections for
their communities. We are also sending this report to each
of the individuals in state governments whom we contacted.
We hope that our compilation of suggestions for improving
the process will be of use to the Environmental Protection
Agency. Finally, in some ways the EPA guidelines are a
"pilot study" of how such a process of developing national
consistency in projections can work. The Office of Manage~
ment and Budget and Department of Commerce will scon be
proposing a similar system to cover all federal programs
which use population projections in funding-allocation
formulas. We hope that our observations and recommendations
will be of use in demonstrating the strengths and weaknesses
of EPA's approach and will therefore enable a federal-wide
system to be a more effective and useful one.



3.5 METHODOLOGIES AND APPROACHES

Methodologies used by states to prepare their projections
and disaggregations varied widely. -

Although most states prepare state projections first, quite

a few prepare projections for substate areas, typically counties
or multicounty economic regions,and then sum those projections
to produce a state projection. Examples of these include:

Utah, Montana, Nevada, New York, South Dakota, and Wyoming.

The methodologies used range from pure demographic projections,
pure econometric ones, with some states using combined
methodologies (see Glossary, Appendix C, for definitions).
Disaggregations include those techniques as well as a variety
of trend and ratio methods.

Although in some cases it was not clear to us what sorts of
methodologies were used at the state level, it seems that
the following states are examples of ones which use certain
techniques to produce state projections:

pure demographic: California, Maryland, Massachusetts,
New Hampshire, South Carolina, Vermont,

and others
pure economic: Colorado
combined: Arizona, Connecticut, Hawaii

Similarly, states prepared the disaggregations using

different techniques, as mentioned atove, and using different
philosophies. They ranged from pure "trend" or "baseline"
projections to more a less inclusion of policy considerations.
See further in this section for definitions. New Jersey's
disaggregations, for example, are prepared as a reflection of
clearly articulated growth policy goals within the state (see
Appendix B).

-50-


In September, 1978 the Environmental Protection Agency
(EPA) published guidelines that fundamentally changed the
process by which population projections are developed

for use in EPA's water quality and air quality programs.

Essentially, the change was as follows: In the past
whatever projection a community or its consultant pre-
pared was accepted as reasonable. This "bottom-up"
approach resulted in projections being used around the
country which totalled several tens of millions more than
the projected U.S. population for 1990 even under the
highest fertility assumptions. Now, however, the orocess
is more a "cascading" or "top-down" one: Each state has
received a federally-prepared projection and all fifty
sum to the Census Bureau's medium projection for U.S.
population growth. The states have until October 1, 1979
to submit to EPA allocations of that projection for parts
of the state. EPA funding for the construction of sewage
createment facilities and related planning efforts for air
and water quality are then tied to those projections.

In spring, 1979 the Sierra Club wanted to inform its members
of the status of state implementation of the population
projections guidelines. EPA at that time did not have
sufficient information on the states to enable this. The
Environmental Protection Agency then agreed to give the
Sierra Club a small grant to conduct a telephone survey of
all fifty states to assess the status of the disaggregations
in each state and provide that information to our members.
It is our hope that this information will enable many more
people around the country to become involved in the process.

In addition, the Sierra Club agreed to compile
problems identified by the states in order to provide
EPA with information which might further improve the
process in the future,

This report is one of the results of that grant.

This project has been financed in part with Federal

funds from the Environmental Protection Agency under
grant number T901018015, The contents lo not necessarily
reflect the views and policies of the Environmental
Protection Agency.


b) Comparing a state~produced number with the EPA pro-
jection and, in some cases, requesting a variance and preparing
the justification. Montana, for example, has 2 set of projections
prepared initially at the county level and summed to produce
a projection for the state. Montana's projection is auch higher
than EPA's and they will be requesting a variance.

¢) Comparing state-produced disaggregations with the
projections prepared by designated 208 agencies. New York,
for example, has made such comparisons and indicated which
designated 208 agencies will receive variances and can use
their current projections in the interim, and which must
immediately modify theirs, In future water quality planning,
designated 208 agencies will have to use the state's projections.
By comparison, California is using a preexisting state projection,
but not the associated disaggregation. Instead, the state will
prepare a disaggregation in such a way that, with the 10% variances
allowed for 208's, each designated area gets the projection
it wants.

d) Preparing a disaggregation «f whatever projection
for the state was available. for example, Alabama had a
preexisting disaggregation but decided to prepare another
because intrastate trends have changed. Perhaps seven to nine
states appear not to have had disaggregations for their
own state projection,

-44-


TEXAS

Date of contact: July 19

lerh Grubb way timate: 42,8:
estimate: 830,000

Director for Planning and Deve lopment FPA projection: 18,069,000

Department of Water Resources, State's projection: — 18,277,000

P.0. Box 13087 Projection submitted: 18,069 ,9007

Austin, Texas 78711
512/475-3921

State Projections:

In the early 'J0s the Division of Planning and Coordination developed geveral

planning projections for health, education, tronsportatfon, water, etc. They

contracted the projections work to the Population Reaearch Center at the
versity of Texas at Austin, They we a demographic model, and project to

the county level. Bean , rrelece &

Spechal Actévites for EMA

For this process they have done a complete new projection for each county.
They com three or four per cent Jower than EPA; so they normalized the
counties proportionately, They didn’t change the state total because they'd
based a Tot of other planning on ft

They issued the disaggregations to couttes and told them to disagrrepate to
208 areas. Except for the Beaumont/Port Arthur area they'd all been
reconciled and certified by Grubb's office. Also the Victoria/Coastal Bend
non-designated area hadn't been settled yet.

They were virtually done with the process.

A loca} activist has sent us a copy of a letter from Dick Whittington, Dep:
Mrector of the Repartment of Water Resources, February 28, 1979, Indicating
that Texas had submitted Ate projections to FPA on Drcember 5, 1978. These
project tons were made by the Repartment and itz predecessors in November, 1976,
and reevaluated In 1977 to 1978, and are the total Iisted above as “state
Projectton". This submission was not mentioned {n our phone interview, and

80 ve do not know the correct reconclHation between the information in this
section and in the previous one.

v

The procedute decribed above of normalizing projections upvards sounds
fortunate. If the new projections reveal that earlier ones were inflated, it
vould be appropriate, in Ifght of the expensive and irreversible consequences
of oversizing, to use this opportunity to institute lwer projections for new
Planning, rather than to tick consistently to inflated fgures.

a .
Date of contact: August 10

Jeannie Watanabe, Assistant 2/77 estimate: 1,268,000
State Planning Coordinator EPA projection: 1,688,000
124 State Capitol state's projection: CPA + 35%?
Salt Lake City UT 841lé projection submitted: EPA + 35% 7

801/533-4659

State Projections

Last year the Governor designated the State Planning Office as responsible
for providing projections to state agencies. They have spent the past year
revising a madel used to produce a complete set of projections in 1975.

The projectSon begins at the multi-comty evel, which approximates Labor
market arean; these are also the 208 planning areas. The model has both 3
demographic and an econometric component. There are no policy inputs:
projects are not assumed unless the EIS 1s completed or construction has

beg.

Drafts have been submitted to various state agencies for their comments.

Special Activities for EPA

Watanabe is developing the case for a vartance and expects Co submit it
together with the substate projections by the end of August. The EPA
projection made certatn assumptions about fertility trends which do not hold
for Utah, and does not “appreciate certain economic changes” tn the state.

-128-

The designated 208 agencies in the state used different methodologies and
Watanabe has been working with their planners to compare the numbers.

The scheduling of the public mecting is contingent on the state's getting
the requested variance. There ere no procedures for how the state will
prepare disaggreations 1f the variance request {s refused.

The state has Issued the required public notice shout the request for a
varlance. However vhen an Interested citizen called on August 17, he was
told that no matertal was ready for him to lock at regarding the amount of
or Justification for the variance.

Bther_ Comments

Utah appears to be asking for the largest percentage
variance by fac of any state, However the state has

80 postponed this process that now, when they want to meet the
deadline, they are apparently giving inadequate public notice.

It makes no sense to announce @ request for a varfance but not

have any materials to show individuals requesting information;

that makes a mockery of the notice requirement.

Lic hearing.

the Sierra Glub’s Utah Chapter has asked EPA to hold a pm


D. Comparing the Projections With Those of 208 Agencies

Many designated 208 agencies have already prepared grojections.
Some have been submitted to EPA in the past and in some cases
approved.

The guidelines deal with the problem that the projection the
state prepares for the 208 agency's part of the state might
not be the same as that agency's own projection. We should
mote here that in some states the 208 agencies began with
state-produced projections,

The guidelines allow the projections to differ in certain
circumstances: 'Where a designated 208 area has, as of June 26,
1978, already prepared a population projection, it may be used
if the year 2000 population does not exceed that of the
disaggregated projection by more than 10 percent.... If the
208 area population forecast exceeds the 10% allowance, the
208 agency must lower its projection within the allowance...."
Any such variances for these agencies are over and above the
projection being used by the state for this process (see
section 2.3 for further discussion).

This whole matter might, at first glance, seem superfluous,
Tf a designated 208 agency already has a projection, why
doesn't the state simply prepare its disaggregation to "give"
that area of the state the number it is already using?

There are several possible reasons a state might not want or
be able to do this:

1, The projection of the 208 agency may be substantially
greater than a projection already prepared by the state
which the state intends to use. This is not an uncommon
occurrence.

2. The projections of all the 208 agencies taken
together with the rest of the state may be sub-

stantially greater than the projection which the
state wants to use or that EPA permits the state
to use.

3, The state may want to project relatively larger populations
for its non-designated areas (for whatever reasons) and
may do so by preparing a disaggregation which gives the
designated areas less than they have prepared.

These possibilities are discussed in greater detail in-
section 2.4 below.


-16-


See
oe nnn
CHAPTER 1

INTRODUCTION

1.1 Sierra Club Involvement in Population Projections
1,2 History of the EPA Projections Guidelines
1.3 Objectives of the EPA Guidelines

1.4 Project Procedures



The sum total of all state projections
used... should be equal to
or reasonably related to
a projection of U.S. population.

Corps unulysts have admitted that, “by making assumptions
about tuture popuiauions and economic growth and then
providing energy sulficient to sustain such growth, the inital
Projections may become Self-fullilliqg prophecy.” But the
Project’ environmental impact statement takes a different,
more simplistic view, iC chums that the population and indus-
tial growth will ovcur whether or net the daar is built and that
the increased availability of power will er stimulate industrial
development,

The Corps did port out, though, that “by presumung that
energy needs must be inet. the opportunity to use the provision
of power as a tool io direct growth toward socially desirable
goals is foregone Io the absence, however, of any such gener-
aily accepted growth goals, seems highly presumptuous to do.
otherwise than plan as to sauisty the energy needs required to
sustain that level of future development deemed most likely?
The statement is somewhat circular, but it does point out
clearly that unless we as a country begin to develop and arucu-
late more clearly our national, regional and local population
and development goals, the de facto growth policy will con-
(nue (0 reflect past (rends-—or the wishes of the most vocal
and opinionated special titeresty.

Howe are to ase population projections intelligently and
correctly sus planning tools rather than as pronouncements
of unalterable preconditions—a lew principles should be
tollowed

The tederal government should continug to produce pro-
jections for the country as a whole that include a runge of in-
terpretations of current trends in US population growth
Morcover the lederal government should seriously consider
producing alternative projections that present a more goal-
oriented attitude towards US. populagon growth, te., that
exhibit alternative population pathy including teruliy and me
grallon assumptions that ace nat naw regarded ay current
tends.

There ts nothing wroag with the federal government coatinu-
Ing to produge a consistent set of populauion and economic
projections for reztons and communine: cording to current
trends (ay does the Bureau of Econonue Analysis for the Water
Resources Council). However, population proyections that are
developed for use by the government un tunding must sausty
the following conditions:

© Projections must be prepared using demographically accept-
able techniques and must be periodically updated, This point
should be ao surprise

@ The stim total at all state proyections used = -a¢ all prayectiaus
for smaller geoyraphical units-— should be equal to or rea:
sonably related to a projection of U.S. population, The sum ot
the parts must approximate the whole:

@ Proyections must take into account the relevance of goals us
well ay trends.

© There must be opportunities for input by state and local gov-
ernments as well as the public.

Ao JANUARY/FEBRUARY 1979

© All federal agencies should use the sume projections in a
community of state

Communitics ntust be eacouraged to prepare and use pro-
jectons that reflect goals, not simply trends This is particuiarly
true for population distribution within a communty but should
also be true for population size itself Implementation of the
Clean Aur Act, Clean Water Act and other nauonal legislation,
has, 19 some communities, ted to this type of innovative think-
ing, but this needs to be encouraged far more than it hus been

Ap the federal government improves its ability (0 articulate
national policies for urban development, protection ot agncul-
tural land, water poltcy, housing, population growth and so on,
these policies should be reflected in its population projections
There ts good news about the federal government's use of popu-
lation projections, The Eavironmental Protection Agency
(EPA) has developed a new and environmentally sound process.
ong that tollows the principles outlined above

The EPA's process begins with (he Census Bureau's “Series
I progection for the United States. This is the medium projec
bon, the ong most often quoted and used. [tts the projection th:
gives a U.S. population ia the year 2000 of 260 million—and
one in which U.S. population never stops increasing The
Bureau ot Econunuc Analysis (BEA) of the Depacunent ot
Commerce periodically prepares a consistent set of population
and economie projections tor more than 600 geographical re.
gions in the country, meluding cach state. ACEPAYS requeat, the
BEA divided the Cenous Bureau's single projection ito SU state
projections. Each state would then divide its proyectioa inte a
number of smaller proyections for regions (such as those with
water quality planning agencies —"208"" agencies) Each re-
yon would further break down the projections tor constituent
counties, cities and sewaue-facility planning areas (°201""
areas), The available tederal funding would be limited to 75% or
85% ob the cost of a tacility whose size would be determined by
the EPA's population projection Communities that wish (0 con
struct larger facilites could do so at their own additional
expense.

The EPA procedure also includes provisions for reasonable
exceptions and variations within strict limits. Environmentalists
have praised the proposed EPA procedure because it involves a
national overview of population proyectiony, because states
have an important role to play; and because communities can
determine where and how they want growth to occur. Implemen-
tation of these regulations would go a long way toward remedy-
ing the problems involved tn the use of population projections.
But much would sail need to be done: state governments and
communities still have their own policies on how population
projections ure prepared and used. More importantly, the devel-
opment of a community consensus on the most enviroamentally
sound and socially beneticial proyections tor therr area is a task
that remains to be accomplished virtually everywhere in the
country. 7

Judith Kunofsky ts president of Zero Population Growth and 1 the
Club’) populanon specialist



missouRt
bate of contact:
John How Land 7/77 estimate: 4,801,000
Diviston of Environmental Quality FA project ton 51225,000
Department of Natural Resourcer state's projection* 11
7.0. Box 1368 projection submitted: 77

Jefferson City, MO 65101
394/751-3241

In the ‘60s the Highway Department Issued project {ons for transportation
purposes (and these were ured five years ago in the "303""vater basin plans)

The State Office of Administration, which is the state planning agency, issued
projecttoms to 1980 and 1990, and recently contracted to the tniversity of
Wesourl to prepare projections to 2000. Thesr previous projections have been
demographic; so it is }ikely that these are, too.

Special Activittes for EPA

There were projections in the 1980 needs survey presented to Congress in
February, 1979, and at first they were going to use these. But then they
Toud out about the Gffice of Administration's new projections and dectded
to use those. They still do not know how Jarge the 2000 projecttons will be,
but the 1980 nnd 1990 projections are within 5Z of EPA. They should recetve
these soon.

They will then give these to the 2085, who are already imder contract vith
continuing 208 funds to disaggregate the commty totals and submit their
Eigures to the Governor by September 26. These figures are on the agenda for
the September wecting of the Clean Water Commisston; they will discuss what
they know by then, and this will be thelr statewide public participation. In
addition, the 208 will submit their disageregations to their own hear

Other Comments

No one else will he using the factlity planning area disaggregations, but other
state departments will probably use the Office of Administration's county
Figures.

It sounds Like they will met the deadline.

’ .
Nowra

Date of contact: August 9

Phil Brooks: TITT estimats 761,000

Research and Information Systems Division EPA projection 802,000

Dept. of Commmity Affairs state's projectton: 935,000

Capitol Station projection submitted: 77

Helena, MT 59601
406/449-2896

State Projections

The Department of Commmity Affairs is the only state agency producing population
projections, and other state agencies therefore presumably use theirs.

The projection is 9 demographic aud econometric model at the county level; the
state projection ts the sumation of those.

An entire series of projections was produced about a year and a half ago. A
more recent set also has been issued.

Spectal Activities for EPA

-118-

Because of various commmications problems, the state has only recently begun
the vork necessary to comply with EPA guidelines.

Recause the guidelines specify that projections available in Jume, 1978 must
be used, the state will use its projections available at that time even though
that projection's forecast for 1980 was exceeded by the estimate for 1978. The
even larger updated atate projection will be used as part of the Just! fication
for the variance request.

The DCA Ls only beginning to compare the projections used by the four
designated 208 agencies with the state's om projections. Jn the event that
they differ, it has not yet been decided how they wiJ1 he reconciled.
Various substate planning agencies vill be consulted during the process.

The state expects to [inish the process no later than the October 1 deadline in
the guidelines.

Other Comments

Montana vas one of the states in which comumications problems with EPA and
vithin state government caused the process to not be begun until summer, 1979.


Analysis

It is our belief that there are several reasons why state
officials have not seen much value in public involvement:

* They are preparing "trend" projections and see the
public as not being able to provide useful data about what
is happening or professional reflection on the technical
methods they are using. These states do not acknowledge
that choosing to use "trend" projections is in itself a
political decision, nor that there are different views on
what is a "trend."

* They have seen no public interest and cannot believe
there would be any. However even in some states where citizens
have tried to become involved, they have in several cases been
unable to find out what the state was doing. See, for example,
the individual state reports for New Jersey and Pennsylvania.
When we ourselves called Delaware, we were explicitly and
incorrectly told by one official that no one in the state
was working on the process, and we suspect that a caller less
persistent than ourselves would probably never have located
a more knowledgeable official. Furthermore, citizens are
not likely to become involved in something which is presented
as a purely technical phenomenon that supposedly neither
influences nor can be influenced by public policy decisions.

*® The state may be negative about the EPA process as a
whole and wants to devote as little energy to it as possible.

* The state regards discussions in the context of 208
plans as sufficient. However in too many cases the public
(as well as state officials themselves) has a mistaken notion
of the "accuracy" or non-controversial nature, supposedly,
of population projections. There would therefore in many
cases be no reason for a 208 advisory committee or others to
spontaneously pay attention to the choices made in producing
projections.

* Although the state's water quality agency is familiar
with and perhaps even sympathetic to public involvement, the
projections are prepared by a "projections agency" which has
no familiarity with how or why to involve the non-governmental
public, may in fact be actively hostile to anything but
professionally prepared "trend" projections, and regards its
task as simply to produce good sets of numbers.

All these reasons are self-reinforcing, for a state which

has failed santil now to involve the public is unlikely even

to see signs of public interest which might encourage further
such efforts on the state's part. As in so many other domains,
the nurturance of public involvement with projections requires
careful attention from the state over the years through many
rounds of updates.


I. How did the Bureau of Economic Analysis produce the
state projections?

The Bureau of Economic Analysis (BEA) produces a set of
projections called OBERS, an acronym for the names of the

two agencizs which originally had responsibility for the
program. The 1972 OBERS projections were published in 1974
and included a consistent set of economic and population fore~
casts for economic areas, water resources regions and subareas,
states, Standard Metropolitan Statistical Areas (SMSA's) and
Non-SMSA portions of the areas. The next complete set is

due in 1979.

For EPA, BEA updated its 1972 projections only at the state
level. They used their economic model to project the state
analogue of gross national product and used state trends to
project per capita income. By relating the two, they developed
a population projection for each state.

They did not do a demographic projection, i.e. one which looks
at fertility and migration trends for the states, That is

type of projections are prepared by the Bureau of the Census.
The most recent set of Census Bureau demographic projections
was wleased in October, 1978, Those projections are different
from the BEA projections and are not involved in the EPA
process. see also question K. below.

J. How does this process relate to the one which will be
proposed by the Office of Management & Budget and Department
of Commerce, which would apply to «ll federal programs which
use projections in their funding decisions?

The EPA guidelines are a separate process. The proposals by
O.M.B. and the Dept. of Commerce are not scheduled to appear

in draft form in the Federal Register until fall, 1979 and

the state projections in that process would not be available
until perhaps 1981. If the OMB proposals are issued in final
form, EPA might then need to revise its own guidelines to

ensure consistency; however the EPA guidelines are in effect now
are will remain so even if the OMB proposals are not issued

in final form.

Of course, many people are looking at the EPA process as a
pilot program of how such a nationally consistent system might
work,


1.3 OBJECTIVES OF THE EPA GUIDELINES

These guidelines appear to have developed over a period
of years because of a variety of concerns:

A. Congressional testimony that the total projections
being used around the country was substantially greater
than any reasonable projection of U.S. population,
and that as a result substantial overbuilding was
taking place.

B. Concern in Congress and the Admini-«trarion that the
size and staging of municipal sewage treatment facilicies
be cost-effective, i.e. produce the most improvement
in water quality per dollar expended:

To the extent that money is used for "reserve capacity”
in one community, it is not available to solve current
water pollution problems elsewhere.

To the extent that a facility is builc which is too
big, the community must bear the burden of excessive
operation and maintenauce costs, as well as its
share of the construction costs.

C,. Concern that the wastewater treatment program could
create new pollution problems by subsidizing sprawl
and loss of agcicultural land and agcravating air and
water pollution - unless the solution is in scale to
the problem being addressed,

D. Concern reflected in the President's Urban Policy, of
which these guidelines are a part, that federal programs
help maintain the integrity of cities and towns.

E. Complaints from a variety of sources that inconsistent
projections are often used in a particular community
among various EPA programs or among the programs of
different federal agencies, In the former case, plans
to meet air quality and water quality standards might be
inconsistent. In the latter, federal programs might be
using projections in such a way that the programs effects
do not reinforcé each other.



2.5 TEXT OF THE GUIDELINES AND DISCUSSION IN THE FEDERAL REGISTER

This section contains thac portion of the Construction
Grants Regulations in the Federal Register of September 27,
1978 which dealt with population projections.

In order are:
* cover page for the entire package of regulations
* two pages of introductory discussion
* three pages of discussion specifically on the public
response to the earlier draft of the projections
guidelines
* text of the guidelines themselves.

-31-


ARIZONA
Pate of contact: August 8

Dean Hoss, Manager 7/77 estimate: 2,206,000
Planning Sect ton EPA prodection: 4,149,000
Bureau of Water Quality Control state's projection: within 5% of TRA
Arizona Dept. of Mealth Services projectton submitted: ”

1740 W. Adams St (poset ly 4,032,200)

Phoenix, AZ 85007 October’ 77 projection

602/255-1252

State Projections

Official state projections are prepared yearly by the Department of Frenomc
Security. All state agencies are required to use these numbers

Projections are prepared for the state and for each county using both
econometric and demographic assumptions. The counctis of government in the
state do projections below the county level, which are used tn state programs.

The projections are reviewed and approved by a Technical Advisory Commi tter
ose members Include representatives of varlous state agencies, local
governments, major universities ,and Indian tribes.

Special Activities for EPA

Oly one of the designated 208 agencies had projections greater than the

state-produced contro] totals. That agency has revised {ts numbers to he
consistent with the state numbers.

Extensive public hearings vere held Last summer, but except for the differenre
in projections mentioned above, the population projections were not the
subject of any concern.

The state number and the disaggregations were submitted fn November, 1978.

' .
ARKANSAS,

Date of contact: July 30

Chuck Rennett 7/77 estimate: 2,144,000

Grants Officer FPA projection: 2,970,000

Construction Grants state projection: 3,032,000

Department of Pollution Contre} and
Ecology

8001 National Drive

Little Rock, Arkansas 72219

projection submitted: 3,032,000

State Projections

There vere no official state projections.

Spectal Activities for EPA

Bennett is responsible for submitting the projections, but the 208 staff,
a different section of the Department of Pollution Control and Ecology,
are the ones responsible for preparing them. They, in turn, bired the
Department of Local Services, which in turn hired the University to do
the work.

The methodology used to produce the projections 1s Inirly complicated,
Involving many rounds of negotiations with local and regional governments:
and planning agencies. According to the state, EPA reguletions required
that the state's 208 program use OBERS (REA) state and substate projections
prepared in 1972 unless those could be shown to be unrealistic. The

state was working with FPA county projections, and was beginning to identi-
fy problems tn parts of the state, where those projections vere too low.
Then in 1977 BEA published a revised projection for the state which was
higher than the former and mich more reasonable, They devised a disaggre-
gation strategy beginning with this newer state projection, county esti-
mates (or projections) from 1972 and 1975,and various comparative rates

of growth and shares of the population.

-106-

Wowrver no county's projection was reduced below the 1972 BFA projection
figures; thus, the original totals of the planning agencies tn this
round of the process exceeded the state projection as allowed hy EPA.
The planning agency projections were reduced roughly proportfonately,
although not in atl cases.

Rennett vas worried because the projections were actually done before
EPA's guidelines came out, and so they were done only to the county

and to the dratnage segment (drainage basin), not to the community.

Mle thinks that Arkansas has already submitted these projections
to EPA, but he's not sure. Bonnett was sure that the state had followed
ALL public partic{pation regulations, but he didn’t know in any detail
what it had done. There were numerous meetings al] over the state, two
advisory committees and tko public hearings, but all these were on water
in general, or water quality standards, not specifically on population.
Bennett did not know of any involvement by environmental groups. or by
local governments either, except for a few representatives on advisory
committees. These projections won't be used for anything else.

Bennett expressed concem over the state's lacking projections down
to the facility planning area for 208's and SHSA's, but Lt appears

that he believed that these were due by October 1. Since they are

not due hy that date, the state seems to be able to meet the deadline,
assuming, of course, that tt meets the public participation requirements.



A.3 MISCELLANEOUS COMMENTS

This is an unplanned planning program. Agencies that work
with HUD are more used to this.

The process is easy for states that are well-prepared but
very hard for others.

The feds want to ignore the energy boom. I'll have to eat
my words EPA accepts our request for a variance.

We have a problem with asking our Governor to accept projections
prepared outside the state. We feel our projections are as
good as EPA's.

The methodology should be reviewed stringently but there should
be some leeway in the actual numbers produced,

EPA needs to be "flexible", particularly at the facilities planning
level (a comment of quite a few states).

-99-


1.4 PROJECT PROCEDURES

Project staff consisted of Judith Kunofsky and Donald Forman
who were based in the national office of the Sierra Club in
San Francisco. Additional volunteers were involved in other
states.

Staff first contacted each Regional Office of the Environmental
Protection Agency and spoke with the individuals who are working
the most closely with the states in complying with the projec-
tions regulations. We spoke with approximately 44 people in

SPA, We asked for their most recent information on the state's
progress in implementing the guidelines and for the name of
their contact in the state.

We then called each of the fifty states, beginning with the
person identified by the EPA staff. In some states, this
person was the one with responsibility for implementing the
process. In other states we were referred subsequently to
various people until we found a person with responsibility
for the projections.

We informed each state that we were preparing a report for

our members on the implementation of the projections guidelines,
and that we were looking for suggestions for improving the
process.

We followed a prepared list of questions, adjusting them to
fit the situations in particular states and omitting certain
low priority questions in the interest of time. The state
calls lasted between twenty minutes and one hour, Notes on
the discussions were almost always retyped within twenty-four
hours of the calls.

The project began on August 9. Phone calls were made during
a six week period between July 16 and August 27. We spoke
with approximately 70 people in the states.



ALABANA

Date of contact: Aupust 6

Gilford Gilder

7177 eattmate: 1
Office of State Manning and perenne
Federal Programs (OSPrr) FPA projectton: 4,160,000

State Capitol
Montgomery, Alabama 36130
(205) 832-6400

state projection: ‘doesn't differ
from BEA by
more than 52°
Projection submitced: same

State Projections

Three years ago 11 southern states tncluding Alabama did a county Jevel
disaggrepation. This vas based on BEA "OBERS F" 1972 projections.
There are no Iegally official projections tn the state, but OSPFP has
Plomoted theirs and they are weed by several state agencies including,
civil defense, education, some parts of the health department, and some
HUD agencies. They are the only consistent set put out with regularity.

Speclal Activities for FPA

They decided to redisaggregate the same totals as hefore because there
have been changes in trends, The new disaggregation and notice of

8 public meeting September 5, just on projections, were sent out August
3. The disaggregation was based almost entirely on census data and
annual estimates.

Other Comments

Apparently the state will meet the FPA deadline with no difficulty.

ALASKA

Date of contact: July 26

Bob Martin 7/77 estimate: 407,000
Construction Grants Engineer EPA projection* 667,000
Department of Environmental Conservation state projection: none

Pouch 0 Projection submitted: 667,000

Juneau, Alaska 99811

State Projections

Special Activity for [PA

They are extremely skeptical about any projections. They think that
EPA Figurer may be Tow, but they say they have no evidence; 60 they
took them, (Martin mentioned existing projections for 2000 ranging
from 500,000 to 1,090,000).

‘They divided the state into six significant population areas, (the
municipality of Anchorage, the four largest boroughs, and “other"),

and went to the Nepartment of Gomerce and Economic Development to get
growth Figures for these. The methodology used a combinatton of
Mstorfe trends and guesswork by Martin, who is not a demographer,

to divide the growth among the six areas. They will be holding meetings
in Jate July or early August on thetr priority Ifst, and projections
wil] be included. Ne didn't think environmental groups were included
on the mailing list for notice for the meetings. Thete has been no
other public participation till now, and local government involvement.

-105-

These disapgregations won't be used for any other purpose.

Other Comments

Maska has some spectal circumstances that make projections there
extremely problematic, in particular, the fact that thelr historic
trends are strongly distorted hy the buflding of the Pipeline, and
the problem that their development is strongly affected by as yet
unmade federal decisions. We can sympathize with their feeling

that this process may be inappropriate to them. Nonetheless, {f

they wish to continue receiving federal wastewater funding, there 1s
a need for some rational decision-making procedure on facility sizing.



GEORGIA
Date of contact: August 15

Tom Wagner 1/77 ext imate 5,048,000 (see be tow)
Office of Panning & Budget EPA projection: 7,053,000

270 Washington St., SW state's projection: 7,053,000

Atlanta GA 30334 projection submitted: 7,405,650
404/656-7191 {exactly EPA 4 5%)

State Projections

The Office of Tlanning & Budget produces offictal state projections.

The most recent set was issued In September, 1977.

The projections are demographic ones at the comty level, and totals for the
state are compared with an independently produced projection for the state.
They include ao goals, and are “baceline” trend projections.

Spechal Activities for EPA

The Office of Planning & Budget has circulated a proposed methodology for
doing the disaggregations to local governments, designated 208 agencies and
other state agencies, and they have come to a preliminary agreement. The
method used will weight three components: a demographic method, an
econometric method, a straight line trend approach, with a ratio method
added aa perhaps a fourth factor.

As of our telephone discussions, they vere heginning to produce the actual

disaggregations, which would also be circulated widely.

OPB vill coordinate the public meetings with the Environmental Protection
Division of the Department of Natural Resources; at least two mretings vould
be scheduled. Thus far non-governmental organizations have not been involved
in the disaggregation proposals.

OPB WAIL not allow other state agencies to we these numbers excent for EPA
programs: The original estimates are not consistent with the state's of {ictal
estimates. The BEA projections include accommodation For the census
undercount in 1970, 2 Factor not taken Into accomt by state projections.
Thetr oun state projections include other details such as ape, tace, and sex
which are used by other programs and not avatlable from the EPA procedures.

Lf the numbers produced are not initlally acceptable to substate governments,
the state may be several months late Jn submitting the disaggrepations to
EPA.

Other Comments

The qiestion of population projections is mich more highly
polteicized in Georgia than, to our knowledge, in any other
atate, Conflicts im particular betueen the Atlanta Regional
Commisston, a designated 208 agency, and the state and FPA
have been going on for many years. These conflicts are the
subject of much press caverage and public debate, and the
different projections are also involved in at least one pending.
Lawsuit regarding a proposed highway expanston.

The current projection of the Atlanta Regional Counc$1 for the
year 2000 Is approximately 3.5 million, while the state's projection
for that area in the same year is approximately 2.4 mUl}Lon,

‘ ,
WAWALL

Date of contact: August #

Robert Schmitt 7/77 estimate: 895,000

Dept. of Planning & Economic Development EPA projection for 2000: 1,366,000

P.O, Rox 2359 state's ow projection: 1,225,900

Honotusu WL 96804 Projection submitted: — 1,223,900

State Projections

Hawaii's Department of Planning & Economic Development prepares official
projections at the state and coumty levels which are used by all state
agenctes and vere weed in the water quality planning process. The Last
set was released in March, 1978 and was submitted to EPA in December, 1978
as part of the 208 pl. There are no plans for an update «til after the
1980 census.

They base thelr projections on economic assumptions pJus assumptions about
fertility. Both the state numbers and disaggregations to the county level
Include some considerations of growth policy and Land wse. For example,
they assume a leveling off of tourism to zero growth in the year 2000. The
question of the population projections is highly political and intensely
debated.

The public 4s involved through Havati's Commisston on Population and the
iawalian future, composed of nine members, seven from the public, one From
atate government (Sclimitt) and one from the Dept. of Defense.

Special Activities for EPA

Schmitt recalJs no particular discussion of the projections in the context
of public hearings on the "208" program.

The state appears to have done nothing new in response to the process.
Other Coments
The state's projections include ships’ crevs and navy personnel while the

EPA projections do not. Therefore Lf a comparable basis were used by the
two agencies, the difference between the projections vould be even greater.

-110-


RHODE ISLAND

Pate of contact: August 20
Chester Symanskt 7/77 estimate: 935,000
Office of State Planning EPA projectLon: 1,033,000
265 Melrose Street state's projection: 1,005,600
Providence, RL 02907 projection submitted: 1,005,600

401/277-2656

Juan Mariscal, for Tom trucker,
208 Project Manager

State Projections

The Statewide Planning Program produces projections for the state and for
comties, clttes, and towns. A set was isaued in 1975 and a revised cet Sn
April 1939.

They use a demographic method at the state level and use a cohort/ratto
method to produce city and town projections. The projectlone ae strictly
baseline projections, vithout policy inputs.

Other state agencles have not been involved in development of the projections
The program is guided by a technical committee and a planning coumctl, both
of which include local government people and private firms, Other than that,
there 1s no public tnvolvemnt.

There 1s an informal policy of state agencies using these numbers.

Spectal Activities for EPA

The 208 program is using the April 1979 project fons.

Symanski was tmavare of the EPA guidelines and referred us to Tom Bruckner,
the 208 project manager. Bruckner was on vacation.

Other Comments

Because Hr. Bruckner was on vacation and apparently would have been the person

mont familiar with the guidelines, Jt was difficult for ue to present a complete
report on the state's process.

The current projections for Rhode Island show substantial population reduction
in the city of Providence, and there appears to br some controversy over a
factlities planning being designed for the city.

The problem of this population reduction might be dealt with more effectively
Af there had been more public tavolvement in considering whether or not the
Projections used should be "current trends" projections or not. Such a dectsfon
seeas to have been made more or less automatically.

. t
SOUTH CAROLINA
Date of contact August 8
George Fowler 1/17 estimate: 2,876,000
Division of Research and EPA project ton: 3,700,000
Statistical Servicer state projection: within 5% of EPA
(803) 758-2586 projection submitted: — same

Webb Linebach

Department of Health and
Environmental Control

2600 Bult St.

Columbia, South Carolina 29201

(803) 75R-3877

Chardes Jeters

Head of Divisson and Industrial
Wastewater

Department of Health and Environmental
Cont rod

2600 Bull Street

Columbia, South Carolina 29201

(803) 758-3877

State Projections

For several years the Division of Research and Statistical Services
has done projections for the state. They've talked mort closely
with the 201 and 208 people in the Department of Health. Their pro-
Jections are within 5Z of EPA's figures. They sre demographic and
to the county. Environmentalists are not involved with this agency,
which desceibes ttself as “Intentially n bit ivory-towertsh.”

Special Activities for EPA

A draft of the county projections was nbout to be released. They
will hold @ public meeting towards the end of September. For
fachiity planning areas, they'l] leave it to the cities and counties
to negotiate reasonable numbers.

-126-


Further, many states reported individual procedures which
were especially effective in generating local involvement.
Since these were by and large the same procedures used to
general public participation, we refer the reader to
section 4.3.

A frequently mentioned problem in many states was the one

or two designated areas that requested exhorbitant pro-
jections. It is difficult for us to find any overall pattern
in how these were handled, i.e. in what cases the state
changed its projections or granted a variance and in what
cases the designated 208 agency is revising its. But,

in most cases, these problems led to serious discussion
between the state and that agency. And since these were
parts of the state where growth is a particularly significant
issue, we regard it as useful in itself that this process

has led to discussions between levels of government.



4.4 WHAT REMAINS TO BE DONE

Although many states will have completed the process of
submitting projections by the October 1 deadline, others will
not. These latter states will still be making decisions on
how to submit their projections.

Many important opportunities for public involvement still
remain:

* When variance requests are submitted, the EPA Regional
Administrator is required to solicit public comment and, if
there is controversy, hold a public hearing. Since quite a
few states are submitting last-minute requests for such
variances, chere is still a chance for public review of the
request and for a hearing to be requested,

* Because public hearings require a 45 day notice, reducible
to no less than 30 days, those states in which hearings will be
held still have time for public participation in that hearing.

* If the variance requests are rejected, in whole or in
part, states will have to prepare new projections.

* Several states seem to be violating even the letter of
the guidelines on the requirement for a public meeting, and EPA
might ask them to go back and hold one or otherwise imprve
public participation.

* The Office of Management & Budget and Dept. of Commerce
are scheduled to propose a similar system for all federal
programs which use projections in their funding formulas, These
proposals are scheduled to appear in the Federal Register this
fall, with several months for public comment and public hearings
around the country. The Sierra Club's newsletter, Population
Report, which is available free on request, will keep readers
up to date on these proposals.

* Several states indicated they will resubmit projections
in the near future, when their state updates are available.
These include Connecticut, Kansas, and Maine.

* All states will have continuing updates of their clean

water and clean air plans, and projections for these will be
periodically updated.

-77-


2.1 A TWO-MINUTE VERSION OF THE GUIDELINES

In the past, population projections were prepared by local
governments or vy consulting engineers preparing to build
a particular sewage treatment facility for the local
government. The population projection for the area to be
served together with information and assumptions about per
capita water use and expected industrial water use are
used in a "cost-effectiveness analysis" which determines
how large a facility should be built initially to maximize
the benefit gained per dollar spent.

Under the Clean Water Act, a sewage treatment facility whose
size is determined by such an analysis is entitled to have 75%
of its construction costs paid for by the federal government.
If the facility uses innovative or alternative technologies,
the federal share of the cost can be 85%. A community can
always build a larger facility as long as the additional
construction costs are paid for in some other way,

The population projections that were prepared in this way
totalled tens of millions of peorle tore than even the high
projection of U.S. population in the year 1990. Furthernore,
they were often inconsistent with projections being used in

EPA or other federal programs in the same community.

EPA's process is now a "cascading" or "top-down" approach.

The Bureau of the Census prepares projections for the U.S. popu-
lation. EPA contracted with the Bureau of Economic Analysis (BEA)
to disaggregate, or allocate, the medium Census Bureau projection
to projections for each of the states. Each state was sent this
projection, and can either accept it or ammeal. Then each

state divides that projection into projections for so-called
"designated 208 agencies" and other parts of the state such

as counties, (Under Section 208 of the Clean Water Act, the
Governor of a state can choose - i.e., designate - certain
substate agencies to develop the clean water plans for their
area. These agencies, which are sometimes regional planning
agencies or counties, are often called "designated 208 agencies”
or "208's". Similarly, Section 201 of the Act sets up the
program of federal funding for construction of publicly owned
sewage treatment facilities. Those facilities are sometimes
called "201 facilities" and the areas they serve "facility
planning areas" or "201 areas." )

Subsequently, each 208 agency or county will prepare projections
for its cities, towns, and facility planning areas. The
projections that come out of this process are the only ones
which will qualify for use in determining how much federal
funding is available.

Since the "reserve capacity" in a sewage treatment facility
can be a major determinant of how much and when and where
growth occurs in a community, it is important for the public
to be involved. -18-


CAL FORNLA

Date of contact: August 8
Robbrt Chung, 7/77 estimate 21,896,000
Office of Planning & Research EPA project ton: 26,786 ,000

1400 Tenth St.
jacramento, CA 95816
916/445-7866 Projection submitted: 27,211,700

state's projection: — 29,287,00(hase line)

State Projections

A state baseline projection is produced by the PopuJation Researen Unit in the
Department of Finance. For the year 2000, the baseline projection 15
29,287,000; one of the alternative projections fer that year #4 27,211,700 and
there are othershigher than the baveline. The latest bareline was released
December 1977 and alternative projections were released July 1978.

These projecttons are purely demographic and are prepared at the state and
county levels, the Latter after sone consultation with local planners. These
numbers are used by some counties and some state agenctes. There arr no policy
inputs.

PubJtc involvement: There usually ts none, although a public meeting was
called by the Office of Planning & Research in early 1977 to discuss the
baseline projection.

Special Activities for EVA

Altnough the Department of Finance prepares the baseline projection and although
the State Water Resources Control Roard oversees the water qualtty planning

and construction grants prograns, spectal activities to comply with the TPA
guidelines are being carried out by the Office of Planning & Research.

OPR WITT not ask to une the state's baseline, hut wilt begin with the state's
lover projection vhich is within 5% of the EPA projection. OPR will, however,
hot use the disaggregation to comties which was prepared by DOF together with
this Jover projection, known as "F-75".

State policy, consistent with the Governor's Urban Strategy, is that state
agencies should use coumcil of government projections, when those projections
have been reviewed and approved by OFR. The state has six designated 208
agencies, vhich are also commctls of government (COG's); of these, al} but one
prepare their own projections. The remaining COG's cover mont, but not all of
the state, and generally use the DOF projections.

The sum of the COG projections plus DOF projections for non-COG comties 1s

Rreater than the 27,211,700 projection. In order to use this projection, &
Preserve the state's commitment to using COG projections, tt appears that the
state will use the allowed 10% vartances for designated 208 agencies.

OPR has heen vorking on a continuing basis for several years
with representatives of other state apencles to develop state
policies on the use of projections. Also, the Department of
Finance briefs state agencies on thelr projections.

OPR plans to discuss the proposed disageregations with the designated
208 agenctes and is in regular contact with the Sierra Club on

this issue. They expect the public meeting to be held sufficiently
quickly that the disageregations can be submitted to FIA not long,
after the October I deadline.

27,21), 200( lover protection)

Date of contact: August 10

Jerry Langin-Hooper 7/77 estimate: 2,619,000

Diviaton of Planning EPA projectton: 3,868,000
Department of Local Affairs state's projection: a
1313 Sherman, Room 520 projection submitted: 4,373,000
Denver, CO (includes some varsances)

303/839-7351

The Division of Planning preduces projections for the state. The Jast official
set was reJeased in April 1976. A preliminary revised set was releaced jn
1978 for comment; provintonal projections vere Issued in early 1979, and a
final set will be released in August, 1979.

The projection is basically an econometric one. The state dors not have good
demographic Information since the 1970 census, particularly on interstate

migrants. The project{ons are trend projections; although there has been much
discussion about state growth policy in recent years, none has been developed.

“A state statute requires agencies not using Division of Planning project fons

to get their approval, but this is not well enforced.

Special Activities for EPA

The state's interagency executive committee which oversees the 208 process set
up an oversight committee and a technical committee to comply with the EPA
guldeLines on projections.

When the projections prepared by derignated 208 agencies were reduced by
about 102, and added to state-produced Etgures for other areas, the total
roughly equalled the state's “central projection.”

The state believes that energy development on the vestern slope of the Rockles
is likely to produce eignificantly more growth than the EPA projection. In

late July, the state submitted a request to use a projection of approximately
4,373,000 for the state, which is 3,868,000 plus the 5% "allowed" by the
regulations, plus 312,000. This includes 30% variances for the designated

208 agencies. Their projection assumes 22,000 oll shale workers and 10,000
coal workers in their Region XI planning area in the year 2000. This project ton
was worked out together with local governments, councils of government.

They issved a public notice through the A-95 review process in newspaper
advertisements, and in a mailing to a few citizens groups which have expressed
interest. The public meeting is scheduled for September 6.

Dinaggregations vere not submitted to EPA at the same time. The ntate has a
“fall-back" disagaregation in the event the state variance request ts
rejected, The state regards these mmbers as being produced only for EPA and
they will not be used for other purposes.

-107-


2.3 FURTHER QUESTIONS

A. Do these guidelines prevent a community from duilding a larger
sewage treatment facility or planning for more population
growth than is in the projection that comes from this process?

No. A community can build a larger facility if it pays for

the addicional capacity itself. Similarly, a community can

plan for larger population growth as long as those larger
projections are the ones used in its air quality and water quality
plans, The guidelines are not restrictions on planning or

on community goals, only on the amount of federal noney available

B. Does this process affect how much money each state gets for
the Construction Grants Program, which funds sewage treatment
facilities throughout the state?

No. The Clean Water Act Amendments of 1977 fix the amount of
money, or rather the percentage of the appropriation, which

is available to each state, The final population projection
prepared under this process therefore does not affect the money
available.

The size of any particular facility, though, and therefore the
relative distribution of money around the state, may be affected.

Suppose, for example, that the state keeps the same priority
list it had before, i.e. des not change its ordering of what
projects it wants to build first. And suppose that the effect
of the guidelines in that particular state is to reduce the
population projections being used by local governments or
planning bodies for this program. Then the effect of the guide-
lines on actual construction is that the state, with its fixed
pool of federal money, can fund more facilities, each of which
receives less federal funding.



3.6 CONSISTENCY OF PROJECTIONS WITHIN THE STATES

At least sixteen and possibly as many as twenty-six states
already have a formal or informal policy of consistency

among the projections used by state agencies - althouch in

a few cases this is not strictly enforced. Almost half the states
are already planning to use the disaggregations prepared

for EPA for other purposes.

Two states, however, specifically do not want these numbers
used by other state agencies. In one case it was because

of disagreement with the population estimate on which

the projection was based, leading to incomparability of

the projections with others used in the state (see section
3.7). In the other case it was because of differences between
the EPA projection and the state's otm, without any problem
with the estimate. A third state expressed reservations
about further use of the disaggregations produced for EPA
because of the "“crudeness of their methodology."

Many of the states commented that their efforts to develop
intra-state consistency are hampered by the varying require-
ments of federal programs. One state referred to state
agencies dealing with the Dept. of Commerce; Dept. of Labor;
kealth, Education & Welfare; and EPA, whose needs and
requirements differ, while other states mentioned HUD programs
and DPT. These states were supportive of federal efforts to
develop consistent requirements since that would serve state
needs as well.

-34-


APPENDIX B

INDIVIDUAL STATE REPORTS

Each state report that follows is the summary of
one or more telephone interviews lasting’ between
twenty and sixty minutes each. Because of
limitations of space we had to omit much of the
information we learned in those calls; we would
be happy to provide additional details on
request on particular states.

"Date of contact" refers to the date of our most

recent telephone conversation with a state representative.
Material in the summaries is therefore no more recent
than that date; because some states were at the time

in the midst of deciding how to handle the projections,
the situation at the time you are reading this aay

be very differenc.

"7/77 estimate" refers to the estimate of population in
July, 1977 used by the Bureau of Economic Analysis
in preparing in preparing their projections for EPA.

"EPA projection” is the projection for the year 2000
for the state prepared by BEA for EPA.

"State projection” is the state's official, or usual,
or only available projection prepared by the state's
projection agency. It may be several years old, or
very recent.

"Projection submitted” is the projection for the state
which has been or will be submitted to EPA. Except
where indicated, it does not include 10% variances which
may be granted to designated 208 agencies.

The section entitled, "State Projections” describes

the state's usual process of developing projections,
independent of EPA requirements. The next section,
"Special activities for EPA" includes projections
developdd as part of EPA planning processes (sach as
208) or specifically to comply with these guidelines
In some cases it was difficult for us to tell in

which of these two categories some activity haa fallen.

In the "Other Comments" section we present, for some
states, a brief analysis of strengths and weaknesses
in a state's approach to the EPA guidelines.

-103-


monitoring requirements. Still others
concurred with the requirements as
written. EPA has worded the regula-
tions to allow considerable Mexidility
{in monitoring so that local conditions
can dictate the extent of the require-
ment within limits designed to ensure
that minimum monitoring to protect
the health of the community is re-
quired.

Concern was expressed that best
practicable waste treatment criteria
were not defined. These Criteria are
defined in chapter II of “Alternative
Waste Management Tectmiques for
Best Practicable Waste Treatment,”
EPA-430/9-75-013, MCD-13, under al-
ternatives employing land application
techniques.

EPA received recommendations that
Ronprofit organizations be deemed ell-
gible for grants and for management
of on-site systems. The dct allows
award of grants only to “public
bodies.” Nonprofit organizations with
the capability and authority to plan,
design, construct, and operate treat-
ment works for public purposes would
be eligible to function tn that capacity
under agreement with the public body.
If the nonprofit organization ts consti-
tuted a public body under State law, it
could qualify for consideration for a
grant (e.; a citizen’s association
which Is officially constituted as a
sewer district).

One comment asked what is a
“number of Individual units,” is there
a maximum number of individual
units, and if there is a dollar ceiling
for individual systems, There ts no ab-
solute dollar ceiling for individual sys-
tems; the law specifically states a
minimum of “one or more principal
residences or small commercial estab-
lishments." The maximum number of
units would be established through se-
lection of the appropriate alternative
Og unconventional technology for Indi-
vidual residences or clusters of resi-
dences. Under the definition elsewhere
in the regulation ($35.915-l(e)), this
technology would be applied in com-
munities of 3,500 population or less, or
highly dispersed sections of larger
communities.

One comment referred to the state-
ment that all individual systems quall-
ty as alternative systems, yet the cost-
effectiveness gwdeilnes provision for
the 115 percent cost preference for in-
novative and alternative systems does
not apply to individual systems. The
law specifically states privately owned
individual systems must cost less than
the cost of providing a system of col-
lection and central treatment.

Other comments recommended more
coordination between EPA and the
Farmers’ Home Administration
(FmHA). Such coordination has al-
ready been initiated; FmH.a’s final de-
cision on projects ls often made pend-

RULES AND REGULATIONS

ing EPA approval of a grant. In addi-
tion, coordination between the two
agencies in areas such as joint applica-
tons, standardization of definitions of
high-cost projects, and other stream-
lining of administrative procedures is
proceeding under the aegis of a White
House working group on rural water
and sewer problems. This coordination
also will be extended to other Federal
agencies through this group.

One comment recommended exten-
sion of grant eligbulity to bathroom
fixtures and plumbing utilizing flow
reduction’ technology. Congressional
intent expressed in the legistative his-
tory is quite clear that commodes or
associated plumbing are not eligible
for grant funding. If eligible, adminis-
trative difficulties and costs would be
very large.

EPA encourages the use of the facili-
ty plan to evaluate every feasible al-
ternative for solution of the water pol-
lution problem whether or not such a
solution involves grant ineligible facili-
ties or methods. Assistance in grants
packaging, construction supervision,
planning and initial training for oper-
ations and maintenance are all gener-
ally grant eligible.

There were several requests to
define terms and concepts more spe-
cifically. This will be done in separate
guidance to be issued at an early date.

Regulatory changes relating to indi-
vidual systems are found in $§ 35 905-
23, 35.917-1(b),  35.917-2(a), 35.918,
35.918-1, 35.918-2, and 35 918-3.

Cost-EFFECTIVENESS ANALYSIS
GuIDeLINes AND RESERVE CiPacity

Background. On February 4, 1977,
EPA published in the Feperat Rects-
TER proposed guidelines to amend and
supplement the Cost-Effectiveness
Analysis Guidelines (Appendix A to 40
CFR, Part 35, Suopart E). That pro-
posed revision was intended to provide
for cost-effective sizes of and suffi-
cient reserve capacity for wastewater
treatment works and. at the same
time, to avoid overdesign. Coverage in-
cluded guidance and alternative proce-
dures for forecasting growth of popu-
lation, for estimating wastewater
flows, for determining cost-effective
construction staging periods, and for
providing extra capacity beyond that
determined to be cost-effective.

Most of the commenters on the pro-
posed revisions, while agreeing in prin-
ciple with the proposal, ralsed ques-
tions or suggested modifications that
convinced the Agency several changes
were warranted. Aiso, additioaal guid-
ance was required to implement sec-
tion 16 (Cost-Effectiveness) and sec-
tion 21 (Reserve Capacity) of the 1977
Clean Water Act. Accordingly, the
EPA revised the Cost-Effectiveness
Analysis Guideiines to Incorporate
these changes, and on April 25, 1978,

- . . »
CBiscussion )
44031

published them as part of a set of in-
terim regulations to implement the
Clean Water Act. These interim guide-
lines were effective as of June 26, 1978.
Commenters on the interim guidelines
suggested revisions that convinced the
Agency to make some additional
changes.

Innovative and alternative technol-
oes. Section 16 of the 1977 Act en-
courages the use of innovative and al-
ternative westewater treatment tech-
nologres by extending grant eligibility
to such projects if the life cycle cost
does not exceed that of the most cost-
effective alternative by more than 15
percent. The Agency's interim guide-
lines called for using option 3 of the
following options for calculating the
cost-effectiveness preference:

1. Use the iife cycle cost of the
entire proposed waste treatment
system as a base for calculating the
cost difference;

2. Apply the 15 percent increase to
innovative and alternative components
(and other differing portions) as com-
pared with corresponding portions of
the least costly noninnovative alterna-
tive: or

Use, as a base, the entire proposed
waste treatment system where the
system primarily (more than 50 per-
cent of its cost) involves innovative or
alternative technoiogies. Should Inno-
vative or alternative components com-
prise 50 percent or less of the system
cost, the calculation base would be
that for option 2.

Some commenters have expressed a
preference for option 2. The Agency
does not concur because option 2
would de difficult to administer and
would also restrict unnecessarily the
number of projects qualifying for the
15 percent preference. The Agency has
rewritten option 3 to state that all pro-
jects with alternative and innovative
components will qualify for the prefer-
ence, except for those in which alter
native or innovative unit processes re-
place conventional processes In 8
treatment plant and account for less
than 50 percent of the cost. This lan-
guage represents a slight liberalization
of option 3, allowing some additional
projects to qualify for the cost prefer-
ence. This revision also clarifies and
simplifies the old language.

Other commenters noted that coiiec-
tion systems common to both the con-
ventional option and alternative tech.
nology system should not be included
in the calculation base. The Agency
agrees and has modified the guideiines
accordingly.

Another commenter noted that the
15-percent cost-effectiveness prefer-
ence must be mandatory rather than
permissive, Both the law and these
regulations mandate a 15 percent mon-
etary cost-effectiveness preference for
all nnovative or alternative projects

FEDERAL 2EGISTER, VOL 43, NO. 183—WEONESDAT, SEPTEMBER 27, 1978

-36-


2.2 A TEN-MINUTE VERSION OF THE GUIDELINES

A. The EPA Projections for the-States

In 1977, the Bureau of Economic Analysis in the Department

of Commerce prepared a population projection for each of the
states. They began with a projection for U.S. population
prepared by the Bureau of the Census, also in the Department
of Commerce, That projection, known as Series II, assumes

an average family size of 2.1 children per woman and 400,000
net migration to the United States. That fertility rate is
higher than the current level and the migration rate is lower.
(See 2.3, Question K, for further discussion o7 the projection).
The projection for the year 2000 is 265,078,000, which is a
20% increase over the 1979 population of about 220,000,000.

A draft projection was send to each state for comment, but
Many states did not respond. Changes were made by BEA in
response to the comments for many of the states. The revised
projection was then sent to the states.

Although BEA will be releasing an updated set of projections
in 1979 as part of its "OBERS" series of projections, those
numbers do not replace the ones sent to the states for use
in the EPA guidelines at this time.

The number each state was sent can be found in Appendix B,
Individual State Reports.

B. State Review of the EPA Projection

Each state must review this projection and has several choices:

1. The state can use the BEA projection, which we refer to in
this report at the "EPA projection."

2. The state can use a projection which the state had already
prepared as of 6/26/78 instead of the EPA projection as long
as the year 2000 population projected is not more than ine
EPA projection plus 5% for the same year, The June 26, i97&

date was when the interim regulations had taken effect.

3. If a state wants to use a projection existing on 6/26/78
but which is more than 5% greater than EPA's or prefers
any projection prepared more recently than that, it
must get EPA agreement to do so. In the terms of the guide-
lines, the state must "request a variance."

Such a request, together with the justification, must be sent

to the EPA Ragional Administrator who will forward it to
the EPA Administrator in Washington, D.C. However, prior to

-19-


4,1 COORDINATION AMONG STATE AGENCIES

The present EPA process appears at first glance to involve

only water-quality planning, but it has important ramifications
well beyond water. Therefore it is vital to its success that
a variety of the branches of state government be involved.

First of all, in many states water quality functions are
divided among more than one agency. In some states these

were all involved, but in others one agency would handle

the process and the other would continue in blissful ignorance.
In some extreme cases the 208 office would be handling
disaggregations and the 201, or construction grants, office
within the same agency wouldn't know about it.

Second, the process is in actuality as much tied to air quality
as to water quality, The guidelines specifically mention
required consultation with agencies doing air quality planning.
Furthermore, future revisions of state implementation plans

for meeting the Clean Air Act requirements must use the same
projections as those used in the 208 plans.

In our telephone interviews we did not specifically ask about
air agency contacts, but from the fact that only three or four
states volunteered any mention of such contacts, we must con-
clude that they were not high in the consciousness of those
implementing this process. Such consultations (or lack there-
of, may not even be meeting the letter of the guidelines).

Furthermore, we do not know to what extent state air quality
agencies (as opposed to the substate ones mentioned in the
guidelines) were involved. In many cases these agencies were
in the same department as the one handling water quality;
however, as we found was the case among water people, mere
co-presence within a department does not ensure communication.



.

Population Projections

How They Are Made... And How

They Make Themselves Come True

JUDITH KUNOFSKY

edged that population growth ty a cause of all environmen:

tal problems ‘The environmental effects of the almost 220
million Americans are compounded by un annual increase of
almost 2 milfion: thy Census Bureau's “mediuin level” forecast
foresees a total population of 296 million in 2025—only 47
years away A growing population intensities pressure on fragile
iand, contributes to pollugon of ar and water, provides the
anpetuy foe the urbaazauon of agricultural land and the coa-
Structiog of an ever-increasing number of power plants, While
growth cates have declined both in this country and in many
other party of the world. overall populatoa continues to
increase.

The way we evaluate how fast the population size is chang-
ing, what progranis might help reduce the growth rate, how bad
(or good) the situation might be in the future is through the use of
Population proyecuons Moreover, for many programs with
significant environmental impact —sewage treatment faciliues,
Mayor water diversion projects, massive regional enersy
development—the population projection for the appropriate re-
gion is used to jusuty the project. fronically, in many cas
Using a projection (his way actually helps bring about the growth
that was foreseyn. In other words, someumes the projection
causes the growth! .

A population projection tor a given geographical area states
what the populanon size and growth rate would be at certain
ics inthe future ECdifters from a population esumate. which
iy usually 2 statement about the pastor current population of ant
area. Projections are prepared for the world, for nations, states,
counties, cities and smaller geographical areas, and can be pre-
pared wil a variety of detarl and sophisagation, Some pros-
ections give only the total number of people: others describe
distribution by age, sex and sometimes race. religion or other
group identification. Pupulaton proyections are prepared using
different models, of mathematcal formulauions, that express
different theories about why and how population size and
growth cates change. Fur example, one might assume that ¢
community's overall population will continue (0 increase at | % a
year. Or ong might make separate assumptions about family
size. mortality, lertdity timing and migration, and apply those
assumptions to a detailed breakdown of the current population
by age und sex. Alternatively, one might relate population
change to a projection of regional job av lity.

A projection ts not a prediction; even in theory, a projection

FB: \EMOS# fifteen years, the Sierra Club has acknowl-

WM JANUARY/ELBRUARY 1979

need noc tell us what is most likely to happen. A projection
reflects the consequences of 2 continuation of erent trends "*
und the extent to which the model chosen accurately mirrors the
real world. The ditference between them is that current trends
always change, and they change, at feast in part, as 4 result of
our evaluation of and reaction to those trends. For example,
approximately one out of five births in che U.S. is to a teenager.
One might prepare a population projection bused on this situa-
toa However, one might feel that as a socrety we will adoot
Programs to change the trend, and therefore project a reduction
in teenage parenting

Population projections are based on much accumulated expe-
rience und are almost always prepared to reflect whut are be-
lieved to be current trends. Of course, itis difficult to distinguish
between a current trend and a short-term aberration in behavior,
tn fertility or migration. [tis important to realize that it is nor a
question of an adequately prepared projection beiny right or
wrong, but simply that the world is much (oo complicated for
there to be a correct guess of the future

Demoyrapher Peter Morrison has written that, *Forecasung
ts least effective when it iy conducted as an exclusively mechan-
ical process. Itis tempting to adopt an approved method, plug in
some numbers, and crank out some more numbers that tell
people what ta do... ft should be possible, however, to um
Prove the odds on making right decisions not only by laboring to
improve the models, but also by sharpening our ability to evalu-
ate and aysess the products of forecasting models. ... Those
who use demographic forecasts must exercise at least ays much
judgment as those who make them."*

Population projections are used in three ways. Projections are
used to give us an idea of population size and growth rates in the
future. We can evaluate whether the U.S. has reached or will
reach Zero population growth, how fast our numbers might be
increasing in the year 2000, what the contribution of immigra-
on at various levels ts to the U.S. population, the significance
of the heavy migration to the Sun Belt, how fast Monterey,
California, is gaining people or how fast another region is tosing
people From these projections we can then evaluate the need for
corrective or supportive actions, the wisdom of adopting various
population policies to change or reinforce trends,

Projections also are used in determining the allocation of
federal funding, the decision to go ahead with or to reject vari-
ous federal, local and stute projects. All major government
investments—such us roads, dams, sewaye treatment plants and



NeW YonK

Date of contact:

Gharles Morrison 7/77 estimate: 17,924,000
Dept. of Environuental Conservation FPA projection: 18,922,000
Room 406 state's projection 19,596,000
50 Wolf Road projection submitted: 19,827,000
Albany, NY 12233 (includes some 10% vartances and
§18/457-4208 some projections For 1995)

The state's Commerce Department regularly prepares projectlons for the state,
milU-county regtons, and counties. The mast recent set was released tn
January, 1978. ALL state agencies are required to use these project fons

he projectSons are demographic ones, prepared initially at the cory level
and summed to a projection for the state

There used to he an interagency planning committee which oversaw the development
of the projections.

Special Activities for EPA

As part of developing the state's 208 program in non-designated arcas, the
Dept. of Environmental Conservation prepared projections for Minor Civil
Divictons (towns, cities, etc.) in the 47 non-designated counties, working with
county planners. Trojections for parts of the state vere reviewed by the 13
Policy Advisory Committees prior to submission to FPA and hearings vere held
around the state. Some of there projections are for 1995, that having heen the
planning period {or some of the substate agenctes.

Each of the state's six designated areas prepared its own population project ions.

DEC has compared {ts oun projections with those produced by the designated
areas. Nine coumttes among the designated ones have projections which are
Breater than the state's and five of them have projections within JOZ; thelr
numbers have been certifted on the condition that they revise them to match
the atate's projection under specified timetables. Four have projectfons more
than 10% above the state's; although their numbers have been certified, they
cannot be used during the interim and must revise them to match the state's

under specified timetables.

The state is preparing a handbook of guidelines for engineering consultants on
how to prepare projections for facilities planning areas to be conaistent with
EPA requirements. This handbook describes the EPA regulations, how the state
Prepared disagrrepations, the role of infrastructure in affecting growth, and
thelr analysis of probleme with the EPA requirements.

According to Hr. Morrison, the certified projections were submitted to EMA In
fall, 1976.

Other Comments

We have seen a draft of one of the sectlons of the handbook being prepared
(eee shove) and think New York atate sould be conmended for its preparation.
It is only when such materials are made available to governments, consultants,
and the public that pollctes on population projections and some mderstanding
Of the Amact of thelr use can be widely shared and debated.

made in the draft,

Although we do not necessarily agree with all the commen’
we wish all states were preparing such reports

‘ .
NORTH CAROLINA
Date of contact: July 30
Steven Wardrup 1/77 estimate: 5,525,000
Seciat Research Assistant 2 FEA projection: 7,419,000
Department of Natural Resources state projections:
and Community Development. high: 7,538,000
Division of Environmental low: 7,080,000,
Management projection submitted: range of
P.O. Box 27687 7,080,000 to 7,538,000

Ralesgh, North Carolina 27611
(919) 739-5251

State Projections

There are tum agencies that do most of the state's population work:

the Division of Environmental Management for federal programs, and

the Division of Administration for in-state use. These each developed
projections. DEM fs consistently higher, which comes from 6 philosophy
that It's hetter in environmenta) planning to overproject. There

were other previous projections not used In this process.

Speckal Activities for ETA

Tt vas decided that the state should submit a range rather than a
single projection, and FPA approved this, Even the igh projections
for all counties total within 5% of EPA. They had just finished the

projections for all counties, held public hearings, and were going to '
fend the projecttons tn soon. g

a
They did two sete of independent projections fer the counties. The .

Division of Aduinistration used demographic methods while DAY used
econometric methods, In Februaty and March they held seven public
hearings on 208 plans. Population was included as a separate agenda
item in these. People had until June 30 to submit coments. They
received comments on twenty of the hundred counties, most from regional
planners, none from the public or environmental groups. Project fons
to facilities planning ateas are handled by local governments a5
needed.

Other Conments

There 1s no state uniform policy on projections, hut there has been
an informal agreement for last ten years to use these project tons
for all environmental planning. Before submitting the projections
they may submit them to the Environmental Management Comission for
approval, ond this would be useful as a step towards establishing
untform statewide projections.


OKLAONA
Date of contact: July 20

David Blackford 7/77 emtimat 2,811,900
QOR project manager) IPA projection? 3,396,000
Chief of Environmental Programs State's projection? BPA 4 5.4%
Department of Pollutton Control projection submit ted: ”

P.0. Rox 52504
Oklahoma City, Oklahoma 73157
405/271-4677

State Projections

The Oklahoma Employment Security Commisston (OFSC) was designated by the
Governor to prepare projections, originally for noting employment trends. They
have several years experience and use combined demographic/econometric
methodology.

Spectal Activities for EPA

The 201 program broke down projections to hydrological bomdaries vhen
different from political ones.

The OFSC projections are 5.4% higher than FA's.

They are preparing thelr work task for this process now. They don’t know which
agency will actually be preparing the projections; Blackford hoped that OFSC
vould take the contract, but Lf not probably it would be fepartment of
Pollution Control Blackford expressed uncertainty whether the state would
rect the deadline. They apparently have heen delayed fn starting by uncertataty
over what they have to do.

Blackford expected that they would request a variance, though that was not
decided.

Local governments will not he involved much til] the 201 process.

Other Comments

Tt is hard to tell whether they will succeed in meting the deadline or prepare
Teasonable projections, because at the time of contact they essentially had
not started or even Figured out what they vere dofng. It wi}] be very difficult

under these circumstances for them to achieve any significant public involvement.

‘ .
OREGON

Date of contacts July UW

Tom Lucas 7/77 ests mat: 2,376,000

Supervisor EPA projection: 3,209,000

Water Quality Planning ntate's project fon: 3,301,000

Department of Environmental Quality projection submitted: ”

P.0. Box 1760
Portland, OR 97207
503/229-5284

State Projections

The Portland State University Center for Population Research prepares comty
Jevel projections for use hy all state agencies. Thefr medim projection Js
within 5% of ECATS.

Back of the 277 Jocal jurisdictions ts required to follow projections approved
by the Land Conservatton ond Development Commasion for severs, water,
transportation, etc. Only 44 of there have been approved to date. The
submission deaddine te not til] July 1, 1980, and some may be Iate.

Spectal Activities for EPA

The state spent 9 long time in virtual paralysis on this process laboring under
the mistaken bellef tiat they needed facility planning area projections hy
October 1. Apparently it was our phone call on July 24 which Informed them
that they did not need these, and galvanized them into action. They decided to
we the Portland State medium numbers for non-designated areas, and the 208s
own projections for the four 208s, Although there ts a problem with one of the
208s: the Gentral Valley area (Salem) has projections that are 55% higher

than the Portland State medium; and it is not clear what will be done there.

-124-

Notices for public hearing or meetings vere to go out the first week of August.

Lucas indicated that though he was fatrly knowledgeable about what the state
was doing, there vas no individual officially in charge.

Other Cooment:

Oregon has been extremely fast in getting construction grants obligated, so
that there may not be any projects on the priority Hist till next year. This
would mean that the state might not take the October 1 deadline as seriously
as others.

It appears that the state will meet the deadline with an adequate ret of
projections, hut this is sheer luck, since as of July 24, they had no idea how
they would met it.




A.5 REACTIONS TO POSSIBLE FEDERAL-WIDE SYSTEM

In our telephone interviews, quite a few of the state people
were aware that the federal government is considering developing
a process to ensure consistent use of population projections by
all federal programs which use projections in funding formulas.

States generally expressed support for the idea of consistent
projections to be used by state and federal programs, with

some commenting on the technical or political hurdles to be over-
come,

Some states were acquainted with the details of the proposals

being developed by the Office of Management & Budget and Department
of Commerce along these lines. In some discussions, the nature

of the conversation led us to tell states about these proposals;

in others the issue never arose.

General Supportive Comments

Sounds rather progressive.

I wish them luck,

The idea has merit but will take time.

All federal agencies should use the same numbers.

There's some practical value to the OMB plan, but also headaches.
There are now (in our state) no official numbers at anv level. The
feds should use the same numbers; every program in DHEW uses 4

different projection.

A very strong, good move as long as there is substantial state
involvement in reviewing the state projections.

-101-


WWWWUWWWWWWW

PEE O©OBUYAUELNE

NEO

CHAPTER 3

SUMMARIES AND CONCLUSIONS : LEAD AGENCIES & EPA

Special State Activities for the Process
General Attitudes

Use of Available Time

Locus of Responsibility Within the States
Methodologies and Approaches

Consistency of Projections Within the States
State Reactions to the EPA Projections
Variance Requests

Communications Problems

Energy-Impact States

Timing of the Requirements

Vision

-41-


Population Projection/ Forecast/ Estimate/ Census

A census is an actual count of the number of people in

an area. The next census will be taken in 1980.

An estimate is a guess of the number of people in an

area prepared between censuses; it is based on any of

a number of indicators of population change: births,
deaths, construction permits, school enroliments, drivers’
Jicenses, estimates of jobs, etc.

A population projection is a guess, or scenario, of how

many people would live in a particular geographical area

at some time in the future. It consists of base data
(census or estimates, current and past fertility, migration,
mortality, etc.), a model (demographic, economic, straight-
line trend, etc.), and assumptions (‘what will the fertility
be in twenty years? How may jobs will there be in this
area?).

A projection is not necessarily a prediction; the latter

is used when the person preparing a projection thinks that

a particular projection is the most likely to happen.
However one can prepare any number of projections, including
those which one thinks involve assumptions unlikely to
materialize,

A forecast is a projection which someone thinks is reasonably
likely to come true. That is, the term involves more of
a commitment of reasonableness than a projection.

A prediction is a best guess. As far as we can tell, no
state agencies ever uo population oredictions.

A baseline projection is one which is used by official
agencies and is regarded as the standard projection to be used,
or one thought of as reasonably likely to occur if "current
trends" continue.

Disaggregation

A disaggregation of a projection is a division of one projection
into projections for smaller geographical areas. So, for
example, a state may prepare a population projection for the
state and then disaggregate (or divide or allocate) to
projections for counties.

-134-


COLORADO

Other Comments,

Zero Population Growth Colorado, Jn a letter Co FPA dated August 20, Is
requesting a ng on the proposed variance for the state. They
raise the following pointe:

4 the vartance request of 317,000 attributed to energy resource
development presums that the President's synthetic fuels program will be
passed and that Colorado wil] meet those production gnats -this despite great
controversy around the country and within the state The projections should
not assume thie development umless and until this program becomes a reality.

# the projections assume that ald new Jobs mean immigration to the
state and that none of the jobs would be filled hy Colorado residents.

+ the State Department of Planning ttself is of the opinion that these
projections should be developed including poJitical considerations, not simply
technical ones. Full public participation is, therefore, very (mportant and
needed.

‘ »
CONNECTS CUT
Dates of contact: August 17 and 20
We, Asst. Director 1/77 estimate: 3,108 000
Comprehensive Planning Division EPA projection: 3,741,000
Office of Policy & Nanagement state projection: 3,773,800

80 Washington St.
Hartford CT 061)5
203/566-3905

Projection submitted: 1,773,800

Fred Ranntck
Water Compliance Unit

Dept. of Enviromental Protection
State Office Bldg.

165 Capitol Ave.

Hartford CT 06115

State Projections

A net of projections for the state and dleaggregations were prepared in
November 1976 by the former State Planning Council, whose respons {bilities
have now been assumed by the Office of Policy & Management. The latter is
currently preparing revised projections wsing a combination demographic
and econometric model.

The legislature adopted a procedure for developing State Plan of
Conservatton and Development ; public hearings were held, the leg
reviewed the text, and it was adopted in May 1979. This forms t
the polictes vhich are being incorporated in the current set of projections.
Those policies Include land and vater use, preservation of agricultural Imd,
and others. The projections will be open for review by substate governments
for another two months.

for

The public has been tnvolved through the regional planning counci}s, which
in Connecticut are state agencies, and through public meetings.

Special Activities for EPA

AlL water
agencies

lity planning in the state, including that of designated 208
has used the 1976 projections ad their disaggregations.

Bannick will look at how the 1976 projections were artopted to see whether a
public meeting is now required. We expects he will simply resubmit the
1976 projections. Schnure indicated the state will want to resubmit the
nunbers when the current revisions in the projections are completed.

-108-


3.2 GENERAL ATTITUDES

Some states found the process helpful:

It's a good idea to tie down projections. It simplified
things.

This is definitely needed in order to avoid :ver~ and
under-design.

The disaggregations make it easier to deal with population
and allow us to spend time on other issues.

Since 1966 we've required county water and sewer plans
that say where and when service will be.... I was happy
to see the EPA guidelines; it gives us more impetus.

Several states thought the process was an annoyance:

The whole thing is a lot of monkey business, an exercise
in futility, an annoyance.

I would like a more "flexible" system, although preserving
integrity and objectivity.

I'm sure we're not the only state that these guidelines
are going to cause trouble.

In some states the projections were sufficiently consistent
or noncontroversial as to have produced little interest on
the state's part in the guidelines,

The remainder seemed to regard it as another federal requirement
with which they were obliged and willing to comply.

Many states and especially many of those which seemed clearest
in their understanding of the regulations and most experienced
in dealing with projections expressed strong support for the
"cascading" structure of the guidelines. Some particularly were
pleased with EPA for having involved the states rather than
going directly to substate governments. One urged EPA to
continue to regard the ststes as the "firsc line of contact"

in resolving intrastate conflicts over projections.

-45-